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CKB Ltd
GDPR Data Retention Policy
December 2019

1. Introduction

This Policy sets out the obligations of CKB Ltd ® and its group brands including Bar Amigos ® and Lanyards Tomorrow ® (“the Company”), a Company registered in England under 07123102 (VAT number 991324508), whose registered address is St. Christopher’s House, Ridge Road, Letchworth Garden City, Hertfordshire, SG6 1PT, England and whose main trading address is Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Hertfordshire, SG6 2TS, regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). The standards of the GDPR are recognised in the UK Data Protection Act 2018, and are thus referenced in this document and will be focused on for so long as this EU law has legal effect in the UK.

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person which is in the possession of, or is likely to come into the possession of the data controller (the Company in this context).

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation. The Company does not handle such data in respect of customers but does for employees.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

a) Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);

b) When the data subject withdraws their consent;

c) When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;

d) When the personal data is processed unlawfully (i.e. in breach of the GDPR);

e) When the personal data has to be erased to comply with a legal obligation; or

f) Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company and third party organisations it uses, the period(s) for which that personal data is to be retained before it is deleted or otherwise disposed of and the criteria for establishing and reviewing such retention period(s) if applicable.

For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy (as applicable).

2. Aims and Objectives

2.1 The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR. This policy applies to both employee and non-employee data subjects. Employee data subjects may be required to provide their details to third party firms (e.g. suppliers) for the purpose of undertaking their role and, as such, the Appendix to this document may not list every interaction which is covered separately under an employee data consent form.

2.2 In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company without adequate justification, this Policy also aims to improve the speed and efficiency of managing data.

3. Scope

3.1 This Policy applies to all personal data held by the Company. Please note that any third-party data processors processing personal data on the Company’s behalf will have their own data privacy and data retention policies. The Company has sought to check third party compliance with the GDPR and an overview of third party involvement is contained in the Appendices to this policy. Please note, however, that whilst supporting transparency, the Company also needs to be mindful of its requirement to protect its business knowledge and security. Should a data subject wish to enquire further about details of third parties the Company works with, etc., please contact the Data Protection Officer at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS. Please also note that this policy does not cover third party operated marketplace sites which the Company may sell goods on such as Amazon which non-employee data subjects may purchase.

3.2 Personal data, as held by the Company is/ may be stored in the following ways and in the following locations:

a) Computers permanently located in the Company’s UK premises;

b) Computers and mobile devices owned by employees, agents, and sub-contractors used in accordance with the Company’s Bring Your Own Device (“BYOD”) Policy;

c) Physical records stored in the Company’s UK premises; and

d) Third party companies processing personal data such as review companies are contained in the Appendix to this policy. The Company also makes use of a third-party server located in the UK (back up files for disaster recovery purposes may be securely stored in the EU meeting data protection requirements) and a third party electronic file share and storage system is covered by the EU-US privacy shield if stored outside the EU. Please refer to the Appendix.

4. Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy/ Employee Data Protection Policy.

4.1 Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

4.2 Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability if possible, and further rights relating to automated decision-making and profiling.

5. Technical and Organisational Data Security Measures

5.1 The following technical measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Date Protection Policy for further details:

a) All emails containing personal data must be encrypted;

b) Personal data may only be transmitted over secure networks;

c) Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

d) Personal data contained in the body of an email, whether sent or received, should be stored securely;

e) Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

f) Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or sent using a secure method of delivery;

g) All personal data transferred physically should be transferred in a suitable container marked “confidential”;

h) No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Company Director;

i) All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;

j) No personal data may be transferred to any employees or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

k) Personal data must be handled with care at all times and should not be left unattended or on view;

l) Computers used to view personal data must always be locked before being left unattended;

m) No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Company Director and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary. Please refer to the Company BYOD Policy;

n) All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted;

o) All electronic copies of personal data should be stored securely using passwords and encryption;

p) All passwords used to protect personal data should be changed regularly and should be secure;

q) Under no circumstances should any passwords be written down or shared between any employees or other parties working on behalf of the Company, irrespective of seniority or department;

r) All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably and practically possible after becoming available; and

s) No software may be installed on any Company-owned computer or device without approval.

5.2 The following organisational measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy/ Employee Data Protection Policy for further details:

a) All employees or relevant other parties working on behalf of the Company can view both their individual responsibilities and the Company’s responsibilities under the GDPR in the Company’s Data Protection Policy;

b) Only employees or other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;

c) All employees handling personal data will be appropriately trained to do so;

d) All employees handling personal data will be appropriately supervised;

e) All employees and other parties working on behalf of the Company handling personal data shall be expected and encouraged to exercise care and caution when discussing any work relating to personal data at all times;

f) Methods of collecting, holding, and processing personal data shall be regularly reviewed;

g) The performance of those working on behalf of the Company handling personal data shall be subject to review;

h) All employees or relevant other parties working on behalf of the Company handling personal data will be expected to do so in accordance with the principles of the GDPR and the Company’s Data Protection Policy;

i) All parties working on behalf of the Company handling personal data must ensure that any and all of their employees are held to the same conditions arising out of the GDPR and as contained in the Company’s Data Protection Policy;

j) Where any party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

6. Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

6.1 Personal data stored electronically (including any and all backups thereof) shall be deleted securely;

6.2 Special category personal data stored electronically (including any and all backups thereof) shall be deleted securely;

6.3 Personal data stored in hardcopy form shall be shredded securely; and

6.4 Special category personal data stored in hardcopy form shall be shredded securely.

7. Data Retention

7.1 As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

7.2 Different types of personal data, used for different purposes, will necessarily be retained for different periods, as set out below.

7.3 When establishing and/or reviewing retention periods, the following shall be taken into account:

a) The objectives and requirements of the Company;

b) The type of personal data in question;

c) The purpose(s) for which the data in question is collected, held, and processed;

d) The Company’s legal basis for collecting, holding, and processing that data; and

e) The category or categories of data subject to whom the data relates

7.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

7.5 Notwithstanding the defined retention periods in the Appendix, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

8. Roles and Responsibilities

8.1 The Company’s Data Protection Officer is the position holder of Company Secretary at Unit 5, Business Centre East, Fifth Avenue, Letchworth Garden City, Herts, SG6 2TS.

8.2 The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy and Employee Date Protection Policy), and with the GDPR and other applicable data protection legislation.

8.3 The Data Protection Officer and relevant colleagues, including the Company Business Development Manager for technical areas, shall be responsible for ensuring compliance with the above data retention periods.

8.4 Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.

9. Implementation of Policy

This Policy shall be deemed effective as of 1st December 2019. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

V3 CKB Ltd GDPR Data Retention policy – effective date 1st December 2019

APPENDIX

DescriptionData RefPersonal/ Non Personal DataData Subject CategoryType of DataPurpose of Data CategoryPurpose of Data DetailRetention Period or Criteria
Third party customer order management systemCKB-DR-01Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressCustomer Order ManagementRequired to process and despatch orderIndefinitely - to allow follow up of any product faults in future
Third party shopping cart providerCKB-DR-02Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressCustomer Order ManagementRequired to process order and store accountIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party server (customer order management)CKB-DR-03Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressCustomer Order ManagementRequired to store ordersIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Google AnalyticsCKB-DR-04Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend, etc26 months
Online AdvertisingCKB-DR-05Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend (conversion tracking), etcIndefinitely - anonymised data
Online AdvertisingCKB-DR-06Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend (conversion tracking), etcIndefinitely - anonymised data
Third party customer service management toolCKB-DR-07Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressCRM Customer ServiceRequired to communicate with customers concerning orders and answer questions concerning orders and productsIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
FacebookCKB-DR-08Personal InformationNon employee data subjectPersonal data including name if user interacts with postsSocial MediaBusiness promotionIndefinitely - allowing for follow up of any product faults in future in the case of a comment made or competition win, for example
TwitterCKB-DR-09Personal InformationNon employee data subjectPersonal data including name if user interacts with postsSocial MediaBusiness promotionIndefinitely - allowing for follow up of any product faults in future in the case of a comment made
InstagramCKB-DR-10Personal InformationNon employee data subjectPersonal data including name if user interacts with postsSocial MediaBusiness promotionIndefinitely - allowing for follow up of any product faults in future in the case of a comment made
PinterestCKB-DR-11Personal InformationNon employee data subjectPersonal data including name if user interacts with postsSocial MediaBusiness promotionIndefinitely - allowing for follow up of any product faults in future in the case of a comment made
LinkedinCKB-DR-12Personal InformationNon employee data subjectPersonal data including name if user interacts with postsSocial MediaBusiness promotionIndefinitely - allowing for follow up of any product faults in future in the case of a comment made
Facebook AdsCKB-DR-13Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend (conversion tracking), etcIndefinitely - anonymised data
Twitter AdsCKB-DR-14Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend (conversion tracking), etcIndefinitely - anonymised data
Pinterest AdsCKB-DR-15Non Personal InformationNon employee data subjectAnonymised dataDigital Marketing & AnalyticsRequired to inform product research, marketing and advertising spend (conversion tracking), etc30 Days
Third party payment facilitatorCKB-DR-16Personal InformationNon employee data subjectPersonal data including name and total order detailPayment GatewayTo facilitate payment being made6 Months
Third party payment facilitatorCKB-DR-17Personal InformationNon employee data subjectPersonal data including name and total order detailPayment GatewayTo facilitate payment being made36 Months
Third party payment facilitatorCKB-DR-18Personal InformationNon employee data subjectPersonal data including name and total order detailPayment GatewayTo facilitate payment being made12 Months
Website extension toolCKB-DR-19Non Personal InformationNon employee data subjectAnonymised dataWebsite search bar historyTool to provide insight into search history on Our Site to inform business purchasing and advertising decisions24 Months
Third party software for location tracking for currency conversionCKB-DR-20Personal InformationNon employee data subjectPersonal data including IP addressCurrency conversionEnhanced website functionality for better user experienceOn during a users time on the website only
Third party address located based on postcodeCKB-DR-21Personal InformationNon employee data subjectPersonal data including address and IP addressCheckout Address VerificationEnhanced website functionality for better user experienceOn during a users time at checkout only
Third party review companyCKB-DR-22Personal InformationNon employee data subjectPersonal data including name, transaction ID, contact details, order details and IP addressCustomer Feedback & Product ReviewsBusiness promotion and product review/ customer service toolIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party review companyCKB-DR-23Personal InformationNon employee data subjectPersonal data including name, transaction ID, contact details, order details and IP addressCustomer Feedback & Product ReviewsBusiness promotion and product review/ customer service toolIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party accountancy firmCKB-DR-24Personal InformationNon employee data subject and employee data subjectPersonal data including name, address, contact details, order details and IP address as well as employee salary information, etcFinancial accountancy and staff payrollFinancial accountancy and staff payrollIn line with financial accounting requirements, currently 6 years
Third party electronic file share and storage systemCKB-DR-25Personal InformationNon employee data subject and employee data subjectPersonal data including name, address, contact details, order details and IP address as well as employee contract infoBusiness OperationBusiness OperationReviewed in line with relevant data categories
Third party anti-virus softwareCKB-DR-26Personal InformationEmployee data subjectPersonal data including IP addressBusiness ProtectionBusiness protection and securityReview at annual renewal time
Third party bankCKB-DR-27Personal InformationNon employee data subject and employee data subjectPersonal data including name and IP address as well as transactional data where relevantBusiness OperationBusiness bankingIn line with financial accounting requirements
Third party bankCKB-DR-28Personal InformationNon employee data subject and employee data subjectPersonal data including name and IP address as well as transactional data where relevantBusiness OperationBusiness bankingIn line with financial accounting requirements
Third party security companyCKB-DR-29Personal InformationEmployee data subjectPersonal data including name and contact details for out of hours contactBusiness ProtectionBusiness protection and securityReview if a change in employee personnel/ an employee asks to be removed from contact list
Third party security companyCKB-DR-30Personal InformationEmployee data subjectPersonal data including name and contact detailsBusiness ProtectionBusiness protection and securityRetain data for as long as there is a contractual need and also thereafter if required or permitted by law
Third party security companyCKB-DR-31Personal InformationEmployee data subjectPersonal data including name and contact details for out of hours contactBusiness ProtectionBusiness protection and securityReview if a change in employee personnel/ an employee asks to be removed from contact list
Third party mailing companyCKB-DR-32Personal InformationNon employee data subjectPersonal data including name and addressBusiness OperationOrder deliveryRetained for as long as it needs it to carry out a particular purpose or meet a particular obligation.
Third party delivery companyCKB-DR-33Personal InformationNon employee data subjectPersonal data including name and addressBusiness OperationOrder deliveryIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Whats AppCKB-DR-34Personal InformationEmployee data subjectPersonal data including name and contact details for out of hours contactBusiness OperationEmergency business communicationReview if a change in employee personnel/ an employee asks to be removed from contact list
Third party IT firmCKB-DR-35Personal InformationNon employee data subject and employee data subjectPersonal data including name, address, contact details, order details and IP addressBusiness OperationIT supportReview if a change in IT support company
Third party e-mail providerCKB-DR-36Personal InformationNon employee data subject & employee data subjectPersonal data inc name,address, contact/order details/IP address & employee infoBusiness OperationCommunicationsReviewed in line with relevant data categories
Third party delivery companyCKB-DR-37Personal InformationNon employee data subjectPersonal data including name and addressBusiness OperationOrder deliveryIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party communication softwareCKB-DR-38Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressBusiness OperationFacilitates delivery of order confirmation e-mailIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party accountancy firm (EU territories)CKB-DR-39Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressFinancial accountancyFinancial accountancyIn line with financial accounting requirements
Third party accountancy firm (non EU territory)CKB-DR-40Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressFinancial accountancyFinancial accountancyIn line with financial accounting requirements
Third party accountancy firm (non EU territory)CKB-DR-41Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressFinancial accountancyFinancial accountancyIn line with financial accounting requirements
Marketplace portal authorised accessCKB-DR-42Personal InformationEmployee data subjectPersonal data including name, address, contact details, proof if IDBusiness OperationMarketplace portal authorised accessReview if a change in employee personnel/ job role no longer requiring portal access
Third party website developersCKB-DR-43Personal InformationNon employee data subjectPersonal data including name, address, contact details, order details and IP addressCustomer Order ManagementRequired to test siteIndefinitely - to mirror third party customer order management system and allow follow up of any product faults in future
Third party delivery companyCKB-DR-44Personal InformationNon employee data subjectPersonal data including name and addressBusiness OperationOrder deliveryRetained in line with statutory and legislative requirements
Third party mobile phone device and software providerCKB-DR-45Personal InformationNon employee data subject and employee data subjectPersonal data including name, address, contact details, order details and IP address as well as employee informationBusiness OperationCommunicationsReviewed in line with relevant data categories
Third party cookie consent facilitatorCKB-DR-46Personal InformationNon employee data subjectPersonal data including IP addressLegal complianceGDPR requirementIndefinitely to provide confirmation of consent at any given time (re-consent is required every 2 months)
Third party business benefit providerCKB-DR-47Personal InformationEmployee data subjectPersonal data including name, address, contact details, and IP addressBusiness benefitsFinancial accountancyRetained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party business benefit providerCKB-DR-48Personal InformationEmployee data subjectPersonal data including name, address, contact details and IP addressBusiness benefitsFinancial accountancyMax 150 years post an individual staff member's data of birth
Staff HR filesCKB-DR-49Personal InformationEmployee data subjectPersonal data including name, address, contact details, emergency contact details, sickness/ health record, application and employment documentation including contracts, pay rates, training and performance reviewsBusiness OperationLegal compliance6 years after employment terminates
Job applicationsCKB-DR-50Personal InformationNon employee data subjectjob application, CV, interview notes, eligibility to work documentationBusiness OperationLegal compliance6 months after notifying unsuccessful candidates of the outcome of their application
Accident recordsCKB-DR-51Personal InformationNon employee data subject and employee data subjectPersonal data including name. Sensitive data concerning accidentBusiness OperationLegal compliance6 years from the date the accident record was made
Third party online training providerCKB-DR-52Personal InformationEmployee data subjectPersonal data including name, contact details and IP addressBusiness OperationStaff Training/ legal complianceIndefinitely with active account
Third party training providerCKB-DR-53Personal InformationEmployee data subjectPersonal data including name and contact detailsBusiness OperationStaff Training/ legal complianceRetained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party communication providerCKB-DR-54Personal InformationNon employee data subject and employee data subjectPersonal data including name, contact details (communication records)Business OperationCommunicationsRetained for as long as necessary to satisfy legal, accounting and reporting requirements
Third party communication providerCKB-DR-55Non Personal InformationNon employee data subjectPhone numbersBusiness OperationCommunicationsIn line with financial accounting requirements

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