Privacy Policy

Identity of the Data Controller

Purchase Direct Limited (We/Purchase Direct) a company registered in England and Wales under company registration number 03090591, whose registered office is located at Wallace House, 4 Falcon Way, Welwyn Garden City, AL7 1TW, is committed to protecting the privacy and security of your personal information.

Purchase Direct is a “data controller” in relation to the data it collects in relation to its Employee Savings Website. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy. We are registered with the UK Information Commissioner’s Office: Registration Number Z532186X.

This policy and notice applies to all users of our Employee Savings website

Please read this notice, together with any other data notice we may provide you on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of personal information we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are ‘special categories’ of more sensitive personal data which require a higher level of protection.

We will collect, store and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.

How is your personal information collected?

We collect data directly from you by you registering to use our Employee Savings Website and you choosing your marketing preferences on your account.

How we will use information about you

  • We use your personal information to communicate with you by email by sending you a monthly newsletter, which contains links to our website.

Change of purpose

  • We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  • Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data sharing

  • Data is shared with our business partner Edenred Limited.

Transferring information outside the EU

  • We do not transfer data outside of the EU.

Data security

We have measures in place to protect the security of your information that include but are not limited to:

  • We use Transport Layer Security (TLS) encryption (also known as HTTPS) for all transmitted data.Our services are hosted by trusted data centres that are independently audited.
  • All web sites have certificates, only secure access is permitted.
  • All users must login to the system.
  • Back office system can only be access using non-default user accounts, and then only from specified locations.
  • Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
  • We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

How long will we use your information for?

  • We only retain and use your personal information until expiry on your membership of the Employee Savings scheme, or if you opt out of receiving email newsletters, if this is earlier.

Rights of access, correction, erasure, and restriction

  • Please update your personal information by updating your preferences and contact details on our website if any of your personal information changes.

Your rights in connection with personal information

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Julie Thurlbourne in writing.

No fee usually required

  • You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

  • We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, such as receiving our email newsletters, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Julie Thurlbourne, or use the link in the email newsletter to unsubscribe. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Use of cookies by Purchase Direct

  • Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
  • We may use cookies in order to improve the user experience of this website, tell us which parts of the websites the users have visited, provide enhanced services and remember the location and language settings for individual users.
  • Most web browsers allow some control of most cookies through the browser settings. You may refuse to accept cookies by activating the settings on your browser. However, if you select this setting you may be unable to access certain parts of our site.

Data Privacy Manager

We have appointed a Data Privacy Manager to oversee compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your personal information, please contact the Data Privacy Manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

CCTV at Purchase Direct Ltd

Purchase Direct has been increasingly concerned about building security since Tesco plc opened a store on site that is accessible to the general public outside of office hours. Purchase Direct has installed CCTV to assist increase the level of security at the premises.

There are four cameras installed external to the building to observe movements in and out of the building. There are five cameras installed the office area at each corner and reception. The cameras are static, do not record audio and cannot follow people around.

Out of hours the CCTV system is actively monitored by a third party. The third party can make use of the speaker systems to warn off would be intruders. Certain key holders also have access to the CCTV system through the internet and can make threat assessments and if necessary contact the police.

Images are stored securely via a third party and held for a reasonable period of time-31 days minimum to a maximum of 365 days.

There are notices alerting visitors to CCTV on site as people drive to the premises.

The person responsible for recording and monitoring CCTV activity is Mr Simon Floyd.

Recording of telephone calls

Purchase Direct Ltd records all inbound and outbound fixed line telephone calls. We do this for any one of the following reasons, without notifying a third party, in order to:

  • provide evidence of a business transaction,
  • ensure that a business complies with regulatory procedures,
  • see that quality standards or targets are being met,
  • prevent or detect crime,
  • investigate the unauthorised use of a telecommunications system, or
  • secure the effective operation of the telecommunications system.

These recordings are only for internal use and are never communicated to a third party without the consent of all relevant parties.

Changes to this privacy notice

We reserve the right to update this privacy policy at any time, and we will notify you of our new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact Simon Floyd, Director, on 01707 299100.

Updated July 2019