When we process your personal data we are required to comply with the Data Protection Act 1998 (“DPA”) until 25 May 2018, and from 25 May 2018, the General Data Protection Regulation 2016 (“GDPR”) (the DPA and GDPR are together referred to as the “Data Protection Legislation”).
Your personal data includes all the information we hold that identifies you or is about you, for example, your name, email address, postal address, date of birth, location data and in some cases opinions that we document about you.
Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.
This fair processing notice provides information about the personal data we process, why we process it and how we process it.
Trans Eastern Freight Limited is the data controller of the personal data you provide.
Why do we process your personal data?
We process your personal data in order to fulfil the contract we have entered into with you, to receive services or goods from you, and/or to provide the services you have requested from us. We may also process your personal data to respond to any queries or comments you submit to us, including via our website.
We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.
We process most of your information on the grounds of our legitimate interests (i.e. fulfilling our obligations to you in terms of consignments, quotations or business queries), fulfilment of our contract with you or to comply with a legal obligation.
If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
Who will receive your personal data?
We only transfer your personal data to the extent we need to. Recipients of your personal data include subcontractors and suppliers with whom we contract to provide you with certain elements of the services and professional advisers.
We don’t transfer your personal data outside of the EEA.
How long will we keep your personal data?
Due to legalities to do with international transport we will need to retain your personal data for 6 years. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 6 year period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.
What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website. These rights apply for the period in which we process your data.
Access to your data
You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
- where the personal data has to be deleted to comply with a legal obligation.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.
Right to restrict processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
- where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
Right to object
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling).
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Our website, App & Customer/Supplier Portals
We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages consumers’ access or visit, and information volunteered by the consumer (such as survey information and/or site registrations). The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested.
Information gathering and use
- When you register for Online.Transef.com, we ask for information such as your name, business/organization name, email address, phone number, and address.
- Trans Eastern Freight uses collected information for the following general purposes: products and services provision, billing, identification and authentication, services improvement, contact, and research.
- No Trans Eastern Freight contact data will be shared with 3rd parties, without a prior consent.
- A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.
- Cookies are required to use the Trans Eastern Freight, member portal and APP service.
Trans Eastern Freight uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Trans Eastern Freight website, member portal and apps. Although Trans Eastern Freight owns the code, databases, and all rights to the Trans Eastern Freight application, you retain all rights to your data.
- Trans Eastern Freight may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Terms of Service.
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website – https://ico.org.uk/concerns/.
If you have any questions or would like more information about the ways in which we process your data, please contact your Trans Eastern Freight contact.