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Policy respecting and relating to personal and other types of confidential and commercial information held by Sartra International Limited in the course of conducting its business activities.
The purpose of this policy is to identify the types of confidential information collected by Sartra International Limited whether personal information from employees or commercial information from customers and suppliers. The Policy identifies the purposes for which that information is collected and held, the uses to which that information may be put and the extent to which that information may be disclosed to others. This Policy also describes the security appropriate for each type of information held and the duration for which that information will be held. Finally, it identifies the way in which any person, employee, customer or supplier whose information we hold may review that information and may, if not satisfied with either that information or these policies make complaint to the designated individual charged implementing this Policy.
Sartra International Limited recognizes its responsibility for the personal and confidential information it collects and holds. These procedures are intended to assure that personal information is given the protection required by the General Data Protection Regulation Act which comes into force on the 25th May 2018. Where information is personal, we, in general collect, use and disclose information subject to the limitations provided for in the Act. Because there are some basic differences, as respecting the collection, use, and disclosure of employee, customer, supplier and third party information we deal with these types of information separately.
1. Customer and supplier information
In relation to the Data Protection Regulation, Sartra International Limited must hold in strict confidence all information acquired in the course of the relationship concerning the business and general affairs of a customer or supplier. At the most general level we collect information:
*** For the purpose of establishing and maintaining customer and supplier contact, and for such purposes as are required by the nature of the matter in respect of which we are engaged.
A: Information collected for the purpose of establishing and maintaining customer or supplier contact may include contact information such as, business address, telephone and fax numbers, email addresses, and Ip addresses. In certain cases, and when customers or suppliers volunteer information relating to the business in which we are engaged we consider that information relates to business activities and is not personal information, but we still hold it confidential as set out in this policy memorandum. This information is used for the purpose of maintaining customer and supplier contacts and to enhance an ongoing business relationship and may include direct marketing activities. It is not disclosed to third parties except as may be required for the purposes of a particular engagement. In no case is it sold or transferred to third parties for valuable consideration. Sartra International Limited maintain this information/data on a password protected server. The information is maintained for an indefinite period of time. We ask Customers and Suppliers who wish to continue their relationship with us to provide us with any updated information they feel necessary to maintain our relationship. Any Customer or Supplier who wishes to have their information deleted from our records may request such deletion and we will comply with all such requests within a reasonable period of time.
B: Information collected for such purposes as are required by the nature of the matter in respect of which Sartra International Limited is engaged relating to Customers or Suppliers is for purposes which may vary depending upon the nature of our engagement. As previously stated we consider that information relates to business activities and is not personal information, but we still hold it confidential as set out in this policy memorandum. We collect addresses and other contact details required to maintain contact with the Customer or Supplier or their representatives for the purpose of gathering information related to our engagement, providing services, and forwarding account details at any given time. In some cases we collect information relating to the financial state of Customers or Suppliers for purposes connected with the engagement. Such contact information may be disclosed to third parties as necessary to advance the objective of the engagement or as is required by law. From time to time we may use your information to contact you with details of products/services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for any reason by writing to us requesting contact stop and we will comply with immediate effect.
This information is maintained in confidential files and is not used for purposes other than those described above.
2. Third party (customer/supplier) information
We collect information relating to Customers and Suppliers who have relevant connections to our business. In some cases, we are required to and do collect information relating to the financial state or condition of such Customers and Suppliers for purposes connected with the engagement. Such contact information is disclosed to other third parties as may be necessary to advance the objective of the retainer or as required by law. You have the right at any time to stop us from contacting you for any reason by writing to us requesting contact stop and we will comply with immediate effect. This information is maintained in confidential files and is not used for purposes other than those described above.
3. Employee information
We maintain information for purposes of personnel administration and such information as is required by government authorities for purpose of taxation or security and providers of benefits under benefit plans maintained by the firm for the benefit of its shareholders, directors and employees from time to time. We retain this information in compliance with the Data Protection Regulation.
A: With regard to personnel administration and applications for employment we collect information from candidates. This includes contact details, relevant educational details, work experience details and background information for security issues. We normally retain this information after a decision has been made unless an unsuccessful candidate asks us not to retain the information. We collect information relating to the job history of employees up to the date of employment. During the course of employment we collect and retain periodic work evaluations where applicable, attendance data and records regarding compensation history. We also collect and maintain contact information regarding relatives and next of kin. This information is used for employer/employee communications and in connection with our continuing evaluation of personnel requirements and performance assessment where applicable. All data is kept in secure files to which only designated administrative personnel have access. We do not sell or transfer this information to third parties for value or consideration. In connection with persons who have left the employ of the company we do maintain the right to provide such information to prospective employers on request, solely for the purpose of assisting such employers in their assessment of an employment application.
B: Government Authorities for Tax and Security purposes – in connection with our obligations under taxation statutes we collect personal information respecting employees, including current address, date of birth, and social security insurance numbers. We are subject to laws that require us to conduct background checks on the persons we employ. We request persons whom we may hire as employees to authorize such back-ground checks as may be required. We use and disclose this information for the purposes specified by legalisation. It is kept in secure files to which only duly authorized personnel have access.
4. Administration of personal information policy and complaints
An officer of Sartra International Limited as designated from time to time by Management will be responsible for ensuring this policy is applied. Any person may on request, and on reasonable notice review this policy and may request access to the personal information we hold on such them. Each person has the right to request a copy of the information we hold about them at any time. In line with the General Data Protection Act we will not make a charge for this service and will return all queries within one calender month. In the first instance any questions or requests for access should be directed to the Managing Director in writing.
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If you have any other questions or concerns please contact us.
Sartra International Limited
Address: 177-179 Forest Road, Ilford, Essex, IG6 3HY
Telephone: +44(0)20 8500 9933
Registered office address: 71 Hayes Hill, Hayes, Bromley, Kent, BR2 7HN
Company Registration No: 1719455