Susan Worner Tours

Privacy Policy

Privacy Notice – Client

SW Tours Limited (‘the Company’) is a specialist Tour Operator which provides tours to clients.

The Company must process personal data so that services can be provided – in doing so, the Company acts as a data controller.

We will only use your personal data in accordance with the terms outlined in our contracts and our privacy notice.

1. COLLECTION AND USE OF PERSONAL DATA

  • You may give your personal details to the company directly, such as by seeking services from us.

In any case the Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of a contract and our privacy notice.

1.1 PURPOSE OF PROCESSING AND LEGAL BASIS 

The Company will collect your personal data and process your personal data for the purposes of providing you with our services.

The legal bases we rely upon when providing and/or offering to provide these services to you are:

Legal Base Example of Purpose
Legal Obligation To comply with law, e.g. HMRC and Tax legislation.
Contractual Obligation To provide our services.
To assist us / you/your company to establish / exercise or defend legal claims.
Legitimate Interest For marketing and public relations in relation to our services;
To improve the services, we offer and provide.
Consent Where we have explicitly obtained your consent to share your data with other clients.
Public Interest Review if it applies where we supply into public sector.
Vital Interest of Data Subject This is unlikely, however in the event of an emergency, the limited information we hold on you would be provided to emergency services as necessary.

 

1.2 RECIPIENT/S OF DATA

Where we need to share your personal data, we have contracts and data sharing agreements in place with the recipients that require them to treat your information as confidential and ensure the continued protection of your data whilst in their possession. The Company will process your personal data with the following recipients:

  • Governing bodies and authorities as required by law;
  • Our software providers;
  • Third party suppliers, e.g. business associates and professional advisers, such as external consultants, technical and IT support functions and independent auditors;
  • Third party, where necessary to protect your vital interest, e.g. emergency services;
  • Marketing technology platforms and suppliers;
  • We may transfer your personal information to a third party as part of a sale of some or all our business and assets to any third party or a part of any business restructuring or reorganisation. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

2. AUTOMATED DECISION MAKING 

The company does not use automated decision- making, including profiling. Should the company intend to change this process you will be notified in advance.

3. DATA ACCESS RESTRICTION AND RETENTION

The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

4. WHERE SERVICES HAVE NOT BEEN PROVIDED 

If we have not provided you/your company with our services, or had valuable contact with you (or, where appropriate, the company you are working for or with) for two consecutive years, your personal data will be deleted from our systems unless; save where we believe in good faith that the law or other regulation requires us to preserve it.

4.1 WHERE SERVICES HAVE BEEN PROVIDED 

Your personal details may be included in a number of documents created during our contract with you/your company. To comply with legal requirements e.g. HMRC, and tax legislation, your data will be kept for 7 tax years directly prior to the last date on which services were provided to you/your company.

Where the Company has obtained your consent to process your personal data and sensitive personal data we will do so in line with the relevant schedule detailed above.

After expiry of that period your data will no longer be kept.

5. SECURITY PRECAUTIONS IN PLACE TO PROTECT THE LOSS, MISUSE OR ALTERATION OF YOUR INFORMATION

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, e.g.:

  • encryption of our services and data;
  • review our information collection, storage and processing practices, including physical security measures;
  • restrict access to personal access to personal information;
  • internal policies setting out our data security approach and training for employees, these include measures to deal with any suspected data breach.

6. YOUR RIGHTS

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by emailing info@susanwornertours.com

7. COMPLAINTS OR QUERIES

If you wish to complain about this privacy notice or any of the procedures set out in it please contact info@susanwornertours.com

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.

 

Privacy Notice – Next of Kin

SW Tours Limited Ltd (‘the Company’) is a specialist Tour Operator providing tours to clients.

The Company must process personal data so that services can be provided – in doing so, the Company acts as a data controller.

We will only use your personal data in accordance with the terms outlined in our contracts and our privacy notice.

1. COLLECTION AND USE OF PERSONAL DATA

  • your personal details have been provided to us by another person (our client who has indicated you as an emergency contact).

The Company must have a legal basis for processing your personal data. We will only use your personal data in accordance with the terms of a contract and our privacy notice.

1.1 PURPOSE OF PROCESSING AND LEGAL BASIS 

The Company will collect your personal data and process your personal data for the purposes of emergency contact in the immediate health and safety interest of our client.

The legal bases we rely upon when processing your personal data are:

Legal Base Example of Purpose
Legal Obligation Does not apply
Contractual Obligation Does not apply
Legitimate Interest To be able to inform client’s relative of an emergency and / or to clarify concerns about their wellbeing
Consent Does not apply
Public Interest Does not apply
Vital Interest of Data Subject To inform client’ relative of an emergency and / or to clarify concerns about their wellbeing

 

1.2 RECIPIENT/S OF DATA

Where we need to share your personal data, we have contracts and data sharing agreements in place with the recipients that require them to treat your information as confidential and ensure the continued protection of your data whilst in their possession. The Company will process your personal data with the following recipients:

  • Governing bodies and authorities as required by law;
  • Our software providers;
  • Third party suppliers, e.g. business associates and professional advisers, such as external consultants, technical and IT support functions, independent auditors
  • Third party, where necessary to protect our client vital interest, e.g. emergency services;
  • We may transfer your personal information to a third party as part of a sale of some or all our business and assets to any third party or a part of any business restructuring or reorganisation. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

2. AUTOMATED DECISION MAKING 

The company does not use automated decision- making, including profiling. Should the company intend to change this process you will be notified in advance.

3. DATA ACCESS RESTRICTION AND RETENTION

The Company will retain your personal data along with our client data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

4. WHERE SERVICES HAVE NOT BEEN PROVIDED TO THE CLIENT

If we have not provided our applicant with services, or not had valuable contact with for two consecutive years, your personal data will be deleted from our systems unless where we believe in good faith that the law or other regulation requires us to preserve it.

4.1 WHERE SERVICES HAVE BEEN PROVIDED TO THE CLIENT

To comply with legal requirements data will be kept by SW Tours Limited for 7 tax years from the last date on which services were provided to your relative.

After expiry of that period your data will no longer be kept by SW Tours Limited.

5. SECURITY PRECAUTIONS IN PLACE TO PROTECT THE LOSS, MISUSE OR ALTERATION OF YOUR INFORMATION

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, e.g.:

  • encryption of our services and data;
  • review our information collection, storage and processing practices, including physical security measures;
  • restrict access to personal access to personal information;
  • internal policies setting out our data security approach and training for employees, these include measures to deal with any suspected data breach.

6. YOUR RIGHTS

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by emailing info@susanwornertours.com

7. COMPLAINTS OR QUERIES

If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Data Protection Officer by emailing info@susanwornertours.com

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.