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The Genuine Dining Co trading as Lunch Cubed GDPR Privacy Notice

(How We Use Your Information)

(V1 May 2018)

INTRODUCTION

On the 25th May 2018 new legislation on Data Protection enters into force – The General Data Protection Regulations 2018 – “GDPR”.

GDPR replaces previous legislation and contains lots of obligations which Genuine Dining Co (GDC) trading as ‘Lunch Cubed’ must fulfil. Many of the Rules are the same as under previous legislation but there is plenty of new material.

GDPR is an EU Directive directly applicable in all Member states without the need for local legislation and with effect from 25th May 2018. However, the UK has decided that it wants the content of GDPR to apply after the UK leaves the EU and has tabled a Bill in the House of Lords which will achieve this objective. At first sight the Bill looks the same as GDPR (with adjustments which the group of companies (GDC) / (Lunch Cubed) believes are mainly not relevant to the groups position) but things change and the group will need to review its position once the Bill becomes law. GDPR, including its preamble, contains some 54,000 words so the group of companies (GDC) / (Lunch Cubed)  hopes you will be understanding if we attempt to reduce that to some succinct explanations at the risk of leaving some questions in Members’ minds. All such questions and doubts can be emailed to the group of companies and the designated company controller. GDPR already allows (GDC), (Lunch Cubed) (“Controller” in GDPR-speak) to introduce operational rules and policies compliant with the new Directive. (If you spot an error please tell us by email.)

GDPR profoundly changes the way the relationship between the group of companies (GG) / (Lunch Cubed)  in relation to the information (data) which the group of companies collects from you and then processes and stores. No data is provided to or accessed by a third party such as an event venue. Most of the law is mandatory but where there are options this notice will identify and explain the option the group of companies (GDC) / (Lunch Cubed)  is using. Many of the terms are rather technical but we need to use specific terms in order to say exactly what GDPR stipulates. The group of companies (GDC) / (Lunch Cubed)  first task is to be a lawful processor of your data.

TYPES OF DATA COLLECTED AND STORED

The Genuine Dining Co (GDC) / (Lunch Cubed) and associated companies are committed to recording accurate personal and company data which primarily consists of the information that is obtained willingly by a person, employee, association or company.

The Genuine Dining Co (GDC) / (Lunch Cubed) does not collect sensitive personal data such as genetic, biometric or health data nor information on race, ethnicity, religion, political persuasion, or sexual orientation. Such sensitive data is known in GDPR as special category data.

The Genuine Dining Co (GDC) / (Lunch Cubed) may use your data to improve you interaction with the group of companies by recording your personal preferences, interests and location.

The Genuine Dining Co (GDC) / (Lunch Cubed)  does not claim it is hacker-proof. This aspect of processing is being reviewed at least annually as well as whenever there is a high profile report of data breach. In the event of there being a data breach the Association undertakes to inform you (as well as any relevant authority) not later than 1 month of the group of companies become aware of the breach. The Genuine Dining Co (GDC) / (Lunch Cubed)  does not believe that the data it holds give rise to any need to report a breach to the Information Commissioner within 72 hours, but it is conscious of the possible need to do so.)  Paper records are also held securely.

TRANSFER AND SHARING OF DATA

The Administrator (which includes any assistant) is the principal processor of your data.

Book-keeping is also done by the Administrator and supervised by an independent qualified authority on whom required legal obligations have been imposed in relation to processing data.

The Genuine Dining Co (GDC)/ (Lunch Cubed)  hires an IT consultant as required but they generally do not require access to the companies data but should that be required it would be under supervision.

The Companies Officers may also wish to look at collected data from time to time that has been supplied willingly.

The Genuine Dining Co (GDC) / (Lunch Cubed)  will not be able to release any personal data about another person, customers, clients, association, employee or company, even a telephone number or email address.

The Genuine Dining Co (GDC) / (Lunch Cubed)  does not knowingly transfer your data outside the EU.

RETENTION OF DATA

The Genuine Dining Co (GDC) / (Lunch Cubed) intends to hold your data throughout a period of 3 (three) years if the companies ‘relationship’ with a person, association, customers, clients, employee or company is broken either mutually or by default.

YOUR RIGHTS

To complain

Ideally The Genuine Dining Co (GDC) / (Lunch Cubed) would wish to try to deal with complaints itself before recourse to any external authority and asks all persons to submit complaints via email to the Information Director, Mark Wetherall. The Genuine Dining Co (GDC) / (Lunch Cubed) is open for any person, association, customers, clients, employee or company where there is data shared to submit a complaint at any time to the office of the Information Commissioner.

To have correct data recorded by The Genuine Dining Co (GDC) / (Lunch Cubed)  

The Genuine Dining Co (GDC) / (Lunch Cubed) will be happy to correct errors.

– To require The Genuine Dining Co (GDC) / (Lunch Cubed) to erase data which it holds about a person, customers, clients, associations, employee or company

The Genuine Dining Co (GDC) / (Lunch Cubed)  will fully respect the new legislation but reminds all associates of the group of companies that the low-level information gathered by The Genuine Dining Co (GDC) / (Lunch Cubed)  is perceived by the group of companies as the minimum needed to provide all parties who deal with The Genuine Dining Co (GDC) / (Lunch Cubed)  with the right level of service.

WEBSITES

This policy applies to all websites held and operated by The Genuine Dining Co (GDC) / (Lunch Cubed).

UPDATES

Whenever this policy is updated a notice will be sent to our companies, clients, customers and employees. This policy will be reviewed not later than May 2019 and annually thereafter.

CONTACT

If you would like to contact us, please contact Mark Wetherall (mark.w@genuinedining.com) write to:

Group Genuine/ Lunch Cubed
7 Coldbath Square
London
EC1R 4LQ

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