GPDR Policy

Inkterior Art is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

Definitions

Business purposes

The purposes for which personal data may be used by us:   Personnel, administrative, financial, regulatory, payroll and business development purposes.   Business purposes include the following: -         Compliance with our legal, regulatory and corporate governance obligations and good practice -         Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests -         Ensuring business policies are adhered to (such as policies covering email and internet use) -         Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking -         Investigating complaints -         Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments -         Monitoring staff conduct, disciplinary matters -         Marketing our business -         Improving services

 

Personal data	‘Personal data’ means any information relating to an identified or identifiable natural person (‘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. Personal data we gather may include: individuals' phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Special categories of personal data	Special categories of data include information about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
Data controller	‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
Data processor	‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Processing	‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Supervisory authority	This is the national body responsible for data protection. The supervisory authority for our organisation is [the Information Commissioners Office].

 

Scope

Who is responsible for this policy?

As our data protection officer (DPO), Laura Gray has overall responsibility for the day-to-day implementation of this policy. You should contact the DPO for further information about this policy if necessary.

Laura Gray

Inkterior Art

168 Breightmet Drive

Bolton

Manchester

England

BL2 6NP

The principles

Inkterior Art shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Our procedures

Fair and lawful processing

 

We will process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle.

 

Controlling vs. processing data

Inkterior Art is classified as a [data controller (and/or) data processor]. We will maintain our appropriate registration with the Information Commissioners Office in order to continue lawfully [controlling (and/or) processing] data.

 

If you are in any doubt about how we handle data, contact the DPO for clarification.

Lawful basis for processing data

Consent

 

We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.

 

1. Contract

The processing is necessary to fulfil or prepare a contract for the individual.

 

2. Legal obligation

We have a legal obligation to process the data (excluding a contract).

 

3. Vital interests

Processing the data is necessary to protect a person’s life or in a medical

situation.

 

4. Public function

Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.

 

5. Legitimate interest

The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.

 

Responsibilities

 

Our responsibilities

• Analysing and documenting the type of personal data we hold
• Checking procedures to ensure they cover all the rights of the individual
• Identify the lawful basis for processing data
• Ensuring consent procedures are lawful
• Implementing and reviewing procedures to detect, report and investigate personal data breaches
• Store data in safe and secure ways
• Assess the risk that could be posed to individual rights and freedoms should data be compromised

What does Inkterior Art do with your information?

 

Inkterior Art does not print off any invoices or orders (unless requested by you) other than an address label for postage purposes.

 

All data is retained on the platform you contact me on (for example Facebook,  Shopify, Etsy, Instagram, Twitter, Paypal), and in an order book for records. This does not leave Inkterior’s property and is stored securely. Copies of postal receipts are kept securely.

 

This information will not be used for any other purposes other than to complete the service purchased, and for Tax purposes.

 

All paper copies of data (proof of postage, and name in order book) is kept in a secure box with lock and key. This in turn is kept at the property address which is always locked and has a working burglar alarm.

 

Online data is kept on password protected devices, with an additional password to gain access to that platform. The DPO is the only person with these password details.

 

• Accuracy and relevance

 

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

 

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.

 

 

Data retention

 

I am legally required to keep accounting records for 6 years and so holding that data also meets Article 6(c) . 

I have an obligation to ensure the data is accurate and that I do not hold more information than is necessary.

 

I do not accept returns or refunds on any personalized or custom orders. For orders where they are ready to buy, I accept returns for up to 14 day after delivery. After this time I will not be able to accept return due to the deletion of your data following my data protection policy and law.

 

Rights of individuals

1. Right to be informed
2. Right of access
3. Right to rectification
4. Right to erasure
5. Right to restrict processing
6. Right to data portability
7. Right to object

 

You have full rights to request actions on the above, unless that data is required by law, to be kept by Inkterior Art.

Subject Access Requests

• What is a subject access request?

 

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

 

• How we deal with subject access requests

 

We will provide an individual with a copy of the information they request, free of charge. This will occur without within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats, and where possible, provide direct access to the information through a remote accessed secure system.

 

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual must be informed within one month.

 

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.

 

• Data portability requests

 

We will provide the data requested in a structured, commonly used and machine-readable format. This will be done free of charge and without delay, and no later than one month. This can be extended to two months for complex or numerous requests, but the individual must be informed of the extension within one month and you must receive express permission from the DPO first.

 

Right to erasure

• What is the right to erasure?

Individuals have a right to have their data erased and for processing to cease in the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected and / or processed
• Where consent is withdrawn
• Where the individual objects to processing and there is no overriding legitimate interest for continuing the processing
• The personal data was unlawfully processed or otherwise breached data protection laws
• To comply with a legal obligation
• The processing relates to a child

How we deal with the right to erasure

We can refuse to comply with a right to erasure in the following circumstances:

• To exercise the right of freedom of expression and information
• To comply with a legal obligation for the performance of a public interest task or exercise of official authority
• For public health purposes in the public interest
• For archiving purposes in the public interest, scientific research, historical research or statistical purposes
• The exercise or defence of legal claims

 

 

The right to object

Individuals have the right to object to their data being used on grounds relating to their particular situation. We will cease processing unless:

• We have legitimate grounds for processing which override the interests, rights and freedoms of the individual.
• The processing relates to the establishment, exercise or defence of legal claims.

 

Third parties

To provide the service you are purchasing from Inkterior Art, the following service providers may be given your information to fully provide the service. (depending where you purchased the service):

 

Etsy

Facebook

Instagram

Shopify

Paypal

Royal Mail (Parcel Force)

Additional courier companies which you will be notified on if you request special circumstance.

Irene Gray if taking orders to the Post office on behalf of Inkterior Art.

 

All third parties have their own data protection policies, Inkterior Art’s policy does not apply to the practices of the third parties I work with, and I therefore have no control over their policies.

 

Below I’ve included where you can find each of the third party’s policies:

 

https://www.etsy.com/uk/legal/privacy/

https://www.facebook.com/about/privacy

https://help.instagram.com/519522125107875?helpref=page_content

https://www.shopify.com/legal/privacy

https://www.paypal.com/en/webapps/mpp/ua/privacy-full

https://www.royalmail.com/privacy-notice