Privacy Policy

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

• we have your explicit consent;
• the processing is in the public interest or in the interest of public health; or
• the processing is necessary to establish, exercise or defend legal claims.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• opting out at: Click here
• using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations outside the BEG group for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

• companies within the BEG group;
• third parties we use to help deliver our products and/or services to you, eg payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg marketing agencies, market research companies or website hosts;
• credit reference agencies;
• our insurers and brokers;
• our bank;
• our IT helpdesk and support provider and other third party data processors for the supply, maintenance and security of our IT, CRM and telephone systems;
• our professional advisors and consultants;
• our distributors, agents and business partners;

We only allow our service providers and other third parties to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data as instructed, not share it with other organisations, hold it securely and retain and destroy it in accordance with our instructions.

We may also need to:

• share personal data with external auditors, eg in relation to ISO accreditation and the audit of our accounts;
• disclose and exchange information with law enforcement agencies, police force and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Links to other websites: Please note, our websites may contain links to other websites that are not part of BEG and thus BEG will not be responsible for any data that is subsequently submitted to other organisations. If you click on a link on our website that takes you to another site, your data will then become subject to the privacy policy of that site.

Entering or visiting our office premises in the UK

We use a digital sign-in application, provided by a third party supplier, at our three office premises in the UK (“Sites”). The application will capture personal data of visitors to the Sites (“Users”).

Users either submit their details manually via the sign-in devices provided at the Site entrances or can choose to download the “Signin App” on their mobile devices to enable automatic sign-in and sign-out.

The personal data captured by the digital sign-in application may include a User’s name, occupation, employer details and e-mail address as well as the date and time a User signed in and out of the Sites.

We believe that the collection and processing of such personal data is necessary:

1. to comply with our legal health and safety obligations in respect of Users while they are present on the Sites;
2. for legitimate interests pursued by us, including:

• security and access control in relation to the Sites in conformance with our Information Security Management System;
• to assist legal proceedings which may result out of access to the Sites, including health and safety, civil and employment tribunal proceedings.

Data collected by the digital sign in application is stored in the UK and retained for 6 months.

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be kept

We will not keep your personal data for longer than necessary.

We assign a retention period to all the personal data that we collect and process based on business need or legal/regulatory requirement in accordance with our document retention policy. Different retention periods apply for different types of personal data.

When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK and EEA

It is sometimes necessary for us to share your personal data outside the UK/EEA, e.g.:

• with our offices or other companies within our group located outside the UK/EEA;
• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK/EEA, please contact us OR our Data Protection Officer (see ‘How to contact us’ below).

How do we protect your personal data?

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our email traffic is encrypted and our cyber security measures include monitoring our systems and patching or removing viruses and malicious software. Our laptops and work stations are encrypted.

All areas of our CRM system are password protected and third party access is strictly controlled and limited to relevant areas of the system. To prevent unauthorised access to your account details, we may require you to provide additional forms of identity.

All our staff receives regular data protection training.

All paper documents are stored securely.

What rights do you have?

You have the following rights, which you can exercise free of charge: