1. Important information and who we are
We will let you know which Shoreham Port entity you have a relationship with and who will be in control of your data when you contact us or purchase a service from us.
2. How we collect data about you
|Automated technologies or interactions||Automated technologies or interactions As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy www.shoreham-port.co.uk/cookies-policy for further details.|
|Group entities||Where we receive your personal data from other entities within the Shoreham Port group.|
3. Personal data of others
4. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been removed. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
|Identity Data||first name, last name, title, role or job title.|
|Contact Data||address, email address and telephone numbers.|
|Technical Data||internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.|
|Usage Data||Usage Data information about how you use our website.|
|Marketing and Communications Data||your preferences in receiving marketing from us and our third parties and your communication preferences.|
|Financial Data||payment details and payment records.|
Special Category Data and Criminal Offences
We do not routinely collect special category data however, depending on the services we are to provide to you, we may need to collect this information. For example, where hosting boat tours we may need to understand your dietary or access requirements. Where we process special category data we do so in accordance with Data Protection Act 2018.
We do not process information in relation to criminal offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, where required 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|Responding to an information request from you||Identity Contact||Necessary for our legitimate interests (to provide information about the Shoreham Port group and what it does)|
|Responding to speculative CVs, requests for work or work experience||Identity Contact Qualification||Performance of a contract with you|
|To investigate and resolve actual and potential claims and complaints against us||Identity Contact||Necessary for our legitimate interests (to ensure complaints are fairly addressed)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Contact Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||Identity Contact Technical Usage Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To send you marketing material including our newsletters||Identity Contact Marketing and Communications||Consent|
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at Info@shoreham-port.co.uk at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, service experience or other transactions.
7. Discolsure of your personal data
We may share your personal data with other entities within the Shoreham Port group in the following scenarios:
- Where Shoreham Port receives your CV or a work experience request, we may forward this to Shoreham Port Solutions or Sussex Port Forwarding who would manage this for Shoreham Port;
- where queries are received by a Shoreham Port group entity which are meant for another Shoreham Port group entity;
- where a Shoreham Port entity are providing services to another Shoreham Port entity.
We may share your personal data with the following third parties:
|Third Party||Basis for sharing information|
|Professional advisers including our lawyers, accountants, insurers and banks.||Where such professional advisors provide services to us.|
|Service Providers acting as processors such as IT and administration service providers (for example Mimecast and CNC).||Where such service providers provide services to us.|
|Companies who manage parking at Shoreham Port sites||To address any parking query or complaint.|
|Mailchimp||Who provide marketing services to us.|
|Local Authorities (as applicable)||To comply with law and regulation.|
8. International transfer
We do not routinely transfer personal data outside the UK.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available upon request.
For more information about the cookies we use, please see our Cookies Policy.
12. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows
|Right to request access to your personal data||This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.|
|Right to request correction of your personal data||This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.|
|This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.||This enables you to ask us to delete or remove personal data in certain circumstances.|
|Right to object to processing of your personal data||Where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object. You also have the right to object where we are processing your personal data for direct marketing purposes.|
|Right to request restriction of processing your personal data||This enables you to ask us to suspend the processing of your personal data in certain circumstance.|
|Right to request transfer of your personal data||This enables the transfer of your personal data to you or to a third party.|
|Right to withdraw consent||Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.|
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. Privacy of children
This website is not intended for children and we do not offer products or services to children. However, we may be required in very limited circumstances from time to time to collect the names and date of birth of children when on boat tours or work experience. We will only share this with the schools or parents/guardians with whom we have received such information and we will delete such data as soon as this is no longer required.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us firstname.lastname@example.org in the first instance.
15. Third-party links
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
|Policy updated by||Kate Tyrer, External Relations Manager||01.09.21|
|Policy reviewed by||Nicky Brown, People Director||06.09.21|
|Policy authorised by||Brian Rousell, Engineering & IT Director||15.09.21|