We at Syra Coffee are committed to protecting and respecting your privacy.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller in relation to any personal data you provide to us is Syra Coffee Ltd of Carrer de la Mare de Déu dels Desemparats, 8, 08012 Barcelona.
Information we collect from you
You may give us information about you by filling in forms on our website or by corresponding with us by phone, email or otherwise. This will include information which you provide to us when you subscribe to our newsletter, such as your name, email address and postcode, or if you participate on any of our social network sites.
We may also collect information about your computer, tablet or mobile, including where available your IP address, operating system and browser type for system administration purposes and information about how you use our website. This is simply statistical data about our users’ browsing actions and patterns, and you will not be identifiable as an individual from it.
How we use your information
We will use your information to:
Ensure that content from our website is presented to you in the most effective manner.
Provide you with information about our products and services and any other information, services or offers which we think may be of interest to you by email (where you have consented to receive such information).
Notify you about any changes to our website or our services.
It is our intention to only send you email communications that will be useful to you and that you want to receive. We may occasionally send notifications of new products, services or offers from us to your designated email address. You may opt out of receiving these notifications from us at any time by opting out through your confirmation subscription email.
Disclosure of your information
We will never disclose your personal data to any third parties except in the circumstances set out in this section.
We use a number of trusted suppliers and service providers to help provide our website and other services to you. We may need to disclose your personal data to them but will only do so to the extent that it is necessary for them to be able provide the services we require.
We may also disclose your personal information:
To other companies within our group (which means our subsidiaries, our holding company and its subsidiaries (as defined in section 1159 of the Companies Act 2006).
In the event that our company, or substantially all of its assets, is sold, in which case we may disclose your personal data to the buyer and you agree that if you have provided us with consent to contact you by email or otherwise, any such buyer shall also be deemed to have received the same consent.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
How we store your data
All information you provide to us is stored on secure servers which are operated by our trusted providers.
Currently all the providers we use to help us provide the website and services connected to it are located within the European Economic Area (“EEA”) but this may change in the future. Although, we will take reasonable steps to inform you of any change to our arrangements in this respect, By submitting your personal data, you agree to it being transferred to, stored and processed outside the EEA for the purposes of providing you with the services connected with this website. We will always aim to ensure that your personal data is processed in accordance with the rules set out under European law or alternatively in accordance with other national or international legislation, systems or contractual provisions which are recognised by the European Union as being adequate to safeguard your personal data.
We will keep your personal information for no longer than is necessary for the purposes for which the personal information was collected.
Transmission of data over the internet
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Links to other websites
We are not responsible for the data collection practices, the privacy policies or the content of websites which are not operated by us, including social network sites. You should contact the operators of those websites directly if you wish to enquire about their privacy practices and policy before providing your personal information to any third party.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
GDPR COMPLIANCE ADDENDUM
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on Friday 25 May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Syra Coffee is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the Spanish Data Protection Bill.
Syra Coffee is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How we are preparing for the GDPR
Syra Coffee already has a consistent level of data protection and security across our organization, however it is our aim to be fully compliant with the GDPR. Our preparation includes:
Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
Policies & Procedures – Revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals
Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
International Data Transfers & Third-Party Disclosures – where Syra Coffee Ltd stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
Data Subject Access Request – we have revised our procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
Data Privacy Notice– we are revising our Data Privacy Notice to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
Obtaining Consent – we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Direct Marketing – we are revising the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc.), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they , meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clear.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we will provide easy to access information of an individual’s right to access any personal information that we processes about them and to request information about.
What personal data we hold about them:
The purposes of the processing
The categories of personal data concerned
The recipients to whom the personal data has/will be disclosed
How long we intend to store your personal data for
If we did not collect the data directly from them, information about the source
The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
The right to lodge a complaint or seek judicial remedy and who to contact in such instances