At Kym’s, we are committed to maintaining the trust and confidence of our visitors to our website and subscribers to our newsletter. Here you’ll find information on how we treat data that we collect from visitors to our website, or when someone subscribes to our newsletter.
Visitors to our Website
When someone visits www.kymsrestaurant.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way, which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. You can find more information on how cookies are used on this website in the Cookies Policy below.
If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Newsletter Sign Up
As part of the registration process for our e-newsletter, we collect personal information. We use that information for a couple of reasons: to tell you about things you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don’t rent or trade email lists with other organisations and businesses.
We use a third party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice.
You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing email@example.com.
Links to Other Web Sites
Access to Your Personal Information
You are entitled to access the personal information that we hold. Email firstname.lastname@example.org for more information.
Changes to this Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated on 25th May 2018.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
How long are cookies stored for?
Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.
Cookies used on the Website
A list of all the cookies used on the Website by category is set out below.
Strictly necessary cookies
These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website.
These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device.
These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
Third party cookies
These cookies allow third parties to track the success of their application or customise the application for you. Because of how cookies work we cannot access these cookies, nor can the third parties access the data in cookies used on our site.
For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from these websites. We don’t control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.
The organisation is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees, referred to as HR-related personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.
The organisation has appointed Ollie Horlick, HR Manager – Ollie@whiterabbitfund.com and Eadaoin McDonagh – email@example.com as the person’s with responsibility for data protection compliance within the organisation. Questions about this policy, or requests for further information, should be directed to her/him.
“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data protection principles
The organisation processes HR-related personal data in accordance with the following data protection principles:
The organisation processes personal data lawfully, fairly and in a transparent manner.
The organisation collects personal data only for specified, explicit and legitimate purposes.
The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
The organisation keeps personal data only for the period necessary for processing.
The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where the organisation relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
Where the organisation processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.
The organisation will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.
The organisation keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:
whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
for how long his/her personal data is stored (or how that period is decided);
his/her rights to rectification or erasure of data, or to restrict or object to processing;
his/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and
whether or not the organisation carries out automated decision-making and the logic involved in any such decision-making.
The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
To make a subject access request, the individual should send the request to Ollie@whiterabbitfund.com or firstname.lastname@example.org. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.
The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual’s data, it may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the organisation to:
rectify inaccurate data;
stop processing or erase data that is no longer necessary for the purposes of processing;
stop processing or erase data if the individual’s interests override the organisation’s legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
stop processing or erase data if processing is unlawful; and
stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organisation’s legitimate grounds for processing data.
The organisation takes the security of HR-related personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. All data processing systems are password protected, limiting access to employees who have appropriate authorisation (HR Manager, Line manager, Operations manager). All individuals, reasons and locations are listed in a separate spreadsheet outlining who and where information is held (available on request to Ollie@whiterabbitfund.com), they are also outlined in the employee privacy notice.
Where the organisation engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
If the organisation discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International data transfers
The organisation will not transfer HR-related personal data to countries outside the EEA.
Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual moves house or changes his/her bank details.
Individuals may have access to the personal data of other individuals in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff.
Individuals who have access to personal data are required:
to access only data that they have authority to access and only for authorised purposes;
not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
not to remove personal data, or devices containing or that can be used to access personal data, from the organisation’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
not to store personal data on local drives or on personal devices that are used for work purposes; and to report data breaches of which they become aware to Ollie Horlick/ Eadaoin McDonagh immediately.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
The organisation will provide training to all individuals about their data protection responsibilities as part of the induction process going forwards and will collect confirmation that policies and privacy notices have been read and understood.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.