Personal data – what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

Who are we?

Redwood Global is the data controller . This means it decides how your personal data is processed and for what purposes.

How do we process your personal data?

Redwood Global complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

We use your personal data for the following purposes: –

• Details on employees, former employees and subcontractors to maintain our records and accounts.
• Sales and Warrantee details to maintain our records and accounts
• To promote the interests of the business, and contact individuals and companies whom we have accessed to have ‘legitmate interest’ in. Having detailed and recorded this in a ‘balancing test’.
• To maintain our own accounts and records
• To inform you of news, events, activities and services currently available at Redwood Global in which you may be interested.

What is the legal basis for processing your personal data?

Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and keep you informed about events.

• Processing is necessary for keeping records for warranties and machines sold or bought. There is no disclosure to any third party without consent.
  Sharing your personal data

Your personal data will be treated as strictly confidential and will only be shared within Redwood Global. We will only share your data with third parties with your consent.

How long do we keep your personal data?

We keep data in for a period of 4 years, unless you ask us to remove your data.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –

•  The right to request a copy of your personal data that Redwood Global hold.
•  The right to request that Redwood Global corrects any personal data if it is found to be inaccurate or out of date;
•  The right to request your personal data is erased where it is no longer necessary for the Redwood Global to retain such data;
•  The right to withdraw your consent to the processing at any time
•  The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable
•  The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
•  The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interest] • The right to lodge a complaint with the Information Commissioners Office. 

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact Details

To exercise all relevant rights, queries of complaints please in the first instance contact the DPO (Data Protection Officer)in writing, we will comply with all requests within 30 days.

Our Data Protection Officer is Douglas Ghinn 01264 721790 Douglas.Ghinn@ForstGlobal.com

Legitimate Interests Assessments

Legitimate interests assessment (LIA) are available on request from the DPO  

ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY 

POLICY STATEMENT

Modern slavery is a crime and violation of our fundamental human rights. It takes various forms, such as slavery, forced and compulsory labour, servitude and human trafficking, all of which have in common the depriving of a person’s liberty by another in order to exploit him or her for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective controls to ensure that modern slavery is not taking place in our own supply chains or business operations.

1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

2 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, subcontracted workers, volunteers, contractors, external consultants, third-party representatives and business partners, and agents.

3 This policy does not form part of an employee’s contract of employment and Redwood may amend it at any time.

RESPONSIBILITY FOR THE POLICY

1.  The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.  The Managing Director has primary and day-to-day responsibility for implementing and monitoring this policy.

3.  All managers are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4.  All staff and suppliers and customers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.

COMPLIANCE

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or even suggest, a breach of this policy. You must notify your line manager immediately if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at any level at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it might occur you must notify your line manager immediately. You should note that we will give support and guidance to our suppliers to help them address any coercive, abusive and exploitative work practices in their own business and supply chains. If you are unsure about whether a particular act, or treatment of workers, or their working conditions within any level of our supply chains constitutes any of the form of modern slavery, you must raise it with your line manager. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR department. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the employment booklet or else contact the HR Department.

TRAINING
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our business relationship with any individuals and organisations working on our behalf if they breach this policy.