The purpose of this policy is to outline how Hadley Shipping Group* (‘Hadley’) has established measures to protect your privacy and information rights. Hadley is committed to protecting the privacy and security of your personal information.
Hadley is a ‘data controller’ which means we are responsible for how we hold and use personal information about you.
References to “Hadley Shipping Group” or “Hadley” in this Policy refer to The Hadley Shipping Group Limited and its subsidiaries.
We recognise that you have rights as a ‘data subject’, and that we have an obligation to uphold these.
This privacy notice aims to outline how we maintain these rights. In particular, it outlines:
Your information rights:
| Right | Explanation |
|---|---|
| Right to be informed | This encompasses the obligation for us to be transparent in how we collect and use your personal data. |
| Right of access | You have the right to access your personal data and supplementary information. |
| Right to rectification | If the information we hold on you is inaccurate or incomplete, you can request we correct this. |
| Right to erasure | You can request we delete or remove personal data where there is no compelling reason us to continue processing. |
| Right to restrict processing | You have the right to request we cease processing your data, if: • You consider it inaccurate or incomplete; • Where you object to processing and we are considering whether we still have a legitimate interest to process it. • Where we don’t need the data for the original reason we collected it, but may need it to support a legal claim. |
| Right to data portability | Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data which will be provided to a third party in electronic form. |
| Right to object | You have the right to object to our processing under certain circumstances. For example, you can object to: • direct marketing (including profiling); and • processing for purposes of scientific/historical research and statistics. |
| Rights relating to automated decision making including profiling | Where we apply automated decision making, we must: • give you information about the processing; • introduce simple ways for you to request human intervention or challenge a decision; • carry out regular checks to make sure that our systems are working as intended. • Information related to automated decision making is contained later in this notice. |
This privacy notice should outline how we are transparent in our processing. Please get in touch with us through the ‘contact details’ section to find out more or to exercise your information rights.
Hadley collects personal information about individuals in the course of running its business and providing services to customers. We collect information primarily from individuals, however we may also collect information from:
Please find below a summary of the information we collect and how we use this information.
| Information we collect | Why we collect this | How we process this |
|---|---|---|
| i. Full name ii. Address iii. Photos iv. Email address v. Marriage status vi. DOB vii. Nationality viii. Passport info ix. Job Title x. NI number xi. Start Date xii. Tax code and salary info xiii. Pension provider and account number xiv. Bank account number xv. P45/other (tax status) | • Contract (of employment) • Communicate (Shareholders, Directors) | • To set up for employment • Pay salary • Provide to banks, lawyers, Companies House and other organisations form required disclosures • Pay dividends to shareholders and send and receive information to and from shareholders • Appoint and manage directors |
| xvi. Health information (including medical conditions, reports and potentially dependents) | Contract (of employment – offers private healthcare) | Provide to insurer |
| xvii. CCTV footage | Legitimate interests | Reviewed for security purposes |
Please find below a summary of who information is shared with and why we share the information. Additionally we show where information is passed overseas:
| Information we collect | Who do we share it with | Why we share it | Transfer overseas |
|---|---|---|---|
| i. Full name ii. Address iii. Photos iv. Email address v. Marriage status vi. DOB vii. Nationality viii. Passport info ix. Job Title x. NI number xi. Start Date xii. Tax code and salary info xiii. Pension provider and account number xiv. Bank account number xv. P45/other (tax status) | • Payroll processer • Pension providers • Insurance brokers • Insurers • Accounting Software provider (Xero) • Companies House • Banks • Investment Houses • Lawyers • Insurance brokers and insurers • IT Backup provider • IT outsource consultant | • Contracts • Legal • Security | Xero is a New Zealand based company |
| xvii. Health information (including medical conditions, reports and potentially dependents) | • Insurance brokers • Insurers | Process health insurance | |
| xviii. CCTV footage | • Insurance brokers • Insurers | Process insurance claims/security |
Hadley will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Notice, unless a different retention period is required or permitted by law. In general Hadley retains information for seven (7) years from our point of last contact. We hold this information to support our legal, tax and regulatory requirements. If you object to this retention, please contact us – details provided in the ‘Contact’ section.
The information collected is not used for any automated decision making.
Hadley applies technical and organisational security measures to ensure information collected is held securely.
Hadley uses this information only to analyse the use of Hadley’s website to help guide improvements. We do not collect any personally identifiable information.
When you visit Hadley’s website, cookies are created, which are small pieces of information that allow us to maintain your connection to the website. Our website may use cookies for detecting what kind of device you have in order to present content in the best way, for a language switch and/or for other purposes. These cookies do not collect or store any personally identifiable information. You can refuse the use of cookies (see below).
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
For further information regarding data captured by Google Analytics, please visit: https://marketingplatform.google.com.
If you would like to opt out of Google Analytics monitoring your behaviour on our site please use this link: https://tools.google.com.
We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future.
If you have given consent for processing, you are free to withdraw that consent. To let us know this is the case please email Hadley using the contact details below.
If you have any questions in respect of this notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access):
Hadley, as data controller, can be contacted as follows:
Email: enquiries@hadleyshipping.com
The Data Compliance Officer can be contacted as follows:
Email: dco@hadleyshipping.com
If you feel that we have responded to your query inadequately, of if you have a further complaint, The Information Commissioner’s Office can be contacted via the following web address: https://ico.org.uk/global/contact-us/