See also: Cookie Policy (opens in new window).
Who we are
Burlington Uniforms Limited, a private company registered in England and Wales with company number 1195047. Our registered office is: 10, London Mews, London, W2 1HY.
If you have any questions about how we look after your personal data, you can contact us:
- In writing, at our London Headquarters: 76 Lockfield Avenue, Enfield, EN3 7PX. Please mark your letter for the attention of the Confidentiality Officer
- By email to this address: gdpr@burlington-uniforms.co.uk
- By telephone on 0208 443 6920, extension 5.
What categories of personal data do we collect?
Individuals about whom we will hold data:
- Wearers
- Supervisors/Managers/Procurement or Ordering Officers
Information that we hold or might hold about individuals:
Wearers | Supervisors/Managers/Procurement or Ordering Officers | Partners in firms ordering from us | Sole traders ordering from us | Individuals ordering from us in private capacity | |
Name | ● | ● | ● | ● | ● |
Job title | ● | ● | |||
Staff number | ● | ||||
Name of employer | ● | ● | |||
Name of businesses | ● | ● | |||
Names of partners | ● | ||||
Nature of business | ● | ● | |||
Type of work | ● | ● | ● | ||
Length of service | ● | ● | |||
Work address | ● | ● | ● | ● | ● |
Work email address | ● | ● | ● | ● | ● |
Work telephone number(s) | ● | ● | ● | ● | ● |
Work fax | ● | ● | ● | ● | ● |
Mobile number | ● | ● | ● | ● | v |
Home address | ● | ● | |||
Home email | ● | ● | |||
Name of supervisor/manager | ● | ||||
Names of employees | ● | ● | |||
Garments ordered | ● | ● | ● | ● | |
Size | ● | ● | ● | ||
Value of spend | ● | ● | ● | ● | ● |
Feedback and comment | ● | ● | ● | ||
Burlington Uniforms’ notes on possibility of adding value or improvement | ● | ● | ● | ||
Medical conditions/disabilities | ● | ● | |||
Credit rating of business | ● | ● | |||
Bank details | ● | ● | ● | ||
Other wearer information if either partner(s) or proprietor are wearers | ● | ● |
How do we collect your personal data?
Sources of Information:
Wearers | Supervisors/Managers/Procurement or Ordering Officers | Partners in firms ordering from us | Sole traders ordering from us | Individuals ordering from us in private capacity | |
Sales orders (email, fax, web, wardrobe management) | ● | ● | ● | ● | ● |
Direct oral or email communication | ● | ● | ● | ● | ● |
Contract documentation | ● | ||||
Tender, PQQ documents, etc. | ● | ● | ● | ||
Contract/account opening documentation | ● | ● | ● | ● | |
Research of information in the public domain (e.g. professional bodies, websites, credit reference agencies) | ● | ● | ● |
Lawful basis for Processing and Use of Data
Customers and Wearers
Burlington Uniforms will hold and process the information it holds for employees of Organisations (where the contract is between Burlington Uniforms and the Organisation as opposed to between Burlington Uniforms and the Employee) for the purposes of fulfilling its obligations under its contract with the Organisation i.e. order processing (picking, procuring or manufacturing correct garments), delivery, assessment of appropriateness of goods supplied etc.
The company will also hold and process personal data for the purposes of providing management information, seeking to provide added value and best value and for identifying means of achieving continuous improvement in goods and service. Personal data will also be held and processed for the purpose of identifying and dealing with complaints and issues.
Personal data may also be used for the purposes of defending any claim brought by any person against Burlington Uniforms in contract or tort.
In respect of the purposes set out above Burlington Uniforms has a legitimate interest in holding and processing personal data as also does the Organisation and do the wearers.
Burlington Uniforms may from time to time be required to produce records of sales containing personal data to Her Majesty’s Revenue and Customs or other government agencies. To this end data is held or processed in anticipation of or compliance with an anticipated legal obligation.
Where Burlington Uniforms enters into a contract with a wearer or has pre-contractual dealings with a wearer it can rely upon the lawful basis that processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Thus we can rely on this lawful basis where we need to process someone’s personal data to fulfil our contractual obligations to them or because they have asked us to do something before entering into a contract (e.g. provide information, illustrations or quotes).
Marketing
Burlington Uniforms may wish to use information that it holds on individuals for the purposes of marketing. Individuals will include partnerships and sole traders and will also include individuals who are employed by companies or other bodies corporate for whom we hold contact details. We may also use information that we hold about wearers in order to hold meaningful dialogue with businesses.
Telephone Calls
We may call individuals and companies with whom we have already done business, those who have visited our website or made other inquiries (i.e. by telephone, fax, email, letter) or those whose information we have obtained through market research.
In calling such individuals we will be relying upon legitimate interest as our lawful basis for this activity. We have a right to run a business and an interest in making and keeping it profitable, providing employment and business for our suppliers and service providers. We balance this against the possibility of causing minor inconvenience to those we contact.
We will not contact those who have registered under the Telephone Preference Scheme, the Corporate Telephone Preference Scheme or who have told us that they do not wish to be contacted. Wherever possible we will obtain actual consent to telephone contact by placing opt in statements on the website or in emails.
Letters, Circulars, Flyers etc.
The same principles and protocols as those set out above will be applied to these means of marketing, save that there is no equivalent to the Telephone Preference Scheme or Corporate Preference Telephone Scheme.
Electronic Communications (emails, texts, faxes etc.)
As well as being governed by the GDPR use of personal information for the purpose of marketing by means of electronic media is also affected by the Privacy and Electronic Communications (EC Directive) Regulation 2003. The effect of this is that we cannot rely on legitimate interest as the lawful basis for processing information for marketing by electronic means. We have to rely on freely given consent. Therefore consent to communicate in this manner will be requested when an inquirer visits our website, places an order through our website, by email or fax.
Cookies
Consent to cookies on our website will be given by visitors through clear affirmative action, such as clicking an opt-in box or choosing settings or preferences on a settings menu. See also: Cookie Policy (opens in new window).
Period for Retention of Data
Clients, managers, supervisors and members of wearer groups
Under this head, Burlington Uniforms will hold data about individuals for eight years following the end of the contract with the customer or eight years of being informed that an individual is no longer a member of a group of individuals about whom we hold data.
The period of eight years has been decided upon having regard to HMRC requirements to hold records for the current year and the six previous financial years.
We have also considered the ordinary time limits in contract and tort for bringing an action. These time limits are six years from the date a cause of action arises or, in the case of fatalities or personal injuries, three years. In the latter case however there is a secondary limitation period which does not begin to run until the claimant has knowledge required for bringing an action for damages in respect of the relevant damage and the right to bring such an action.
We have taken into account the need to have information available to monitor performance, seek continuous improvement and to provide management information and ad hoc reports to the customer.
Inquirers
Under this head we are thinking of circumstances where personal information is provided to us to enable us to answer pre-contract inquiries, submit tenders, quotes etc. In the circumstances that an inquiry is made but no contract results, information will be deleted six months after the last correspondence.
Access to and Sharing of Data
Information held about individuals will only be accessed or viewed by the following persons:
- ·Directors, managers and other authorised employees
- Properly appointed and authorised consultants
- The company's accountants, solicitors or other professional advisers
- Any court of recognised jurisdiction or any person to whom such court orders data to be disclosed
- Such government departments and agencies to whom the Company is from time to time required to provide data
- Our carriers (delivery details only)
- Where there is a contractual nexus with an individual with banks and clearing houses so that we can process payments.
When we share your personal data, we make sure that it remains secure:
- We conduct a data security review of third parties we share your personal data with to ensure that they will keep your personal data secure and confidential to the standards you and we would expect
- Every external business we work with is required to have a contract with us which clearly describes our expectations about the way in which they keep your personal data secure, the purposes for which they can use your personal data and which holds them fully responsible for meeting those expectations
- We will only send to third parties the personal data that is necessary for the purposes for which it is required.
Rights of Data Subjects
The rights of Data Subjects are set out in the GDPR and the Data Protection Act 2018 and are as follows.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
The following rights are the most pertinent in our principal/client relationship
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR and Data Protection Act.
We must provide individuals with information including: our purposes for processing their personal data, our retention periods for that personal data, and whom it will or might be shared with.
Where we obtain personal data from other sources (e.g. personal data about wearers from a supervisor), we will provide individuals with privacy information within a reasonable period of obtaining the data and no later than one month.
Right of Access
Under the GDPR and the Act, individuals have the right to obtain confirmation that their data is being processed; access to their personal data; other supplementary information which corresponds to information to be provided under the right to be informed and which should be contained in a privacy statement.
You can access the personal data we hold on you by contacting writing to us or emailing gdpr@burlington-uniforms.co.uk. To process your request, we will ask you to send us two forms of proof of identity so that we can be sure we are releasing your personal data to the right person.
We will process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy. If a request is received by email we will normally respond in electronic format unless otherwise requested.
If we consider the frequency of your requests is unreasonable, we may refuse to comply with your request. In those circumstances, we would notify you of your right to complain to the Information Commissioner's Office.
Right to Erasure
Individuals have the right to have their personal data erased if the personal data is no longer necessary for the purpose for which we originally collected or processed it; we are relying on consent as the lawful basis for holding the data, and the individual withdraws their consent; we are relying on legitimate interests as our basis for processing, the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing; we are processing the personal data for direct marketing purposes and the individual objects to that processing; we have processed the personal data unlawfully (i.e. in breach of the lawfulness requirement of the 1st principle); or we have to do it to comply with a legal obligation (e.g. a contractual provision).
The request of the data subject has to be balanced against the data controller’s own legal obligations or potential legal obligations. Having regard to the provision concerning Period for Retention of Data it is unlikely that we would agree to erase data before the period therein defined.
Update
We may update this statement from time to time to take account of any new business activity or to reflect any changes in law or best practice in relation to data protection. We will notify you if we do so.