Privacy Policy and Cookies

Contents

1. Introduction
2. Who we are – companies and websites within scope
3. The kind of data we hold about you
4. Collection of personal data
5. Lawful basis for the processing of personal data
6. Sharing your personal data
7. International transfers
8. How long do we keep your personal data?
9. Security measures
10. Your rights as a data subject
11. Do you have to provide your personal data to us?
12. Automated decision-making and Cookies
13. Do we use your personal data for marketing?
14. Cookies consent management
15. Contact us
16. Complaints
17. Changes to this privacy notice

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us.

This privacy notice/policy explains how we collect and use your personal data, during and after your relationship with us, in accordance with our obligations under data protection legislation. It also covers who we share it with and what rights you have with regards to your personal data and how you can exercise those rights.

2. Who we are – companies and websites within scope

For the purposes of the General Data Protection Regulation (“GDPR”) Bunzl UK Limited trading as Woodway is the Data Controller. The scope also includes personal data that is collected through our websites, by telephone, through Live Chat and through any related social media applications. This means that we determine what data is collected, how this data is going to be used and how this data is protected.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please use the information supplied in the Contact Us section below.

3. The kind of data we hold about you

We may collect, store, and use the following categories of personal data about you (please note this list is not exhaustive):

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
Business contact details such as position, company name, company address, business contact information such as telephone number and email addresses
Age/Date of birth
Bank account details and tax/vat status information
For credit arrangements, other data relating to trading information
Where you visit our site or have deliveries from us, CCTV footage and other information obtained through electronic means such as geolocation data for deliveries
Cookie information and information about your use of our information and communications systems

4. Collection of personal data

We collect personal data from you for one or more of the following purposes:

To fulfil a contract that we have entered into with you or with the entity (or organisation) that you represent. In these circumstances it may be your entity (or organisation), rather than yourself, that has provided us with your personal data
To initiate and complete commercial transactions with you, or the entity (or organisation) that you represent, for the purchase of products and/or services
To deliver product you have purchased directly or indirectly from us
To communicate with suppliers of goods and services
Keeping accounts and other business records
To carry out marketing, electronic or otherwise including sharing within the Bunzl group
Complying with legal or regulatory requirements including health and safety obligations
Dealing with complaints or queries from our customers and our suppliers
Generating data analytics to monitor and improve the performance of our website
To ensure the security and safe operation of our websites and underlying business infrastructure
We may also collect additional information from third parties including credit reference agencies

Technical and Cookie information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet
Your login information, browser type and version, cookies, time zone setting, browser plug-in types and versions
Operating system and platform
Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through and from our site

In section 10 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

5. Lawful basis for the processing of personal data

We believe that it is in our legitimate interests, or is necessary for the performance of a contract, or we obtain consent to collect and use personal data to operate our business and to provide a service that you have requested. In some cases, we may be under a legal duty to use or disclose personal data, for example to comply with a request from an official body.
When we process on the lawful basis of legitimate interest, we ensure our interests and fundamental rights do not override your interests.

6. Sharing your personal data

We may share your personal data, but this will be done on a ‘need to know’ basis and only where it is necessary to do so or where we are required to share information. Such as our professional advisors and service providers including:

Accountants
Legal counsel
Consultants
Insurers
Information technology and communications service providers.
Suppliers
Logistics and transport services.

We may also share personal data:

With any competent law enforcement or regulator as require by law
When we buy or sell any businesses or assets.

We aim to put the necessary safeguards in place to ensure that personal data that the company is legally responsible for remains properly protected and is used appropriately when in the hands of a third party.

We may share personal data when we buy or sell any business or assets. We aim to put the necessary safeguards in place to ensure that personal data that we are legally responsible for remains properly protected and is used appropriately when shared with third parties.

7. International transfer

We are a global organisation and use third parties located in other countries to help us run our business, including other companies within the Bunzl Group in some circumstances. This includes countries outside the “EU” and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data.

8. How long do we keep your personal data?

We will take steps to keep your data for only as long as is necessary for our business needs and in compliance with any legal or regulatory duties to retain personal data for a particular period. However long we retain personal data for, we will ensure it is subject to appropriate security.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Security measures

We will implement measures to protect your data, including appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those individuals, agents, contractors and other third parties who have a business need to know. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

Information Security Statement

Information security at Bunzl is governed by our Global Information Security Policy. We have a multi-layered approach to network and email security from firewalls, servers through to workstation protection and work with best of breed security partners, and vendors, who provide us with the necessary knowledge, tools and technology to support our multi-layered security and network architecture.
We have implemented a blend of controls using people, processes and technologies from industry leading suppliers. We actively monitor these controls to ensure their effectiveness and to highlight deficiencies and highlight improvements.
Patching is undertaken routinely and we have a dedicated security team responsible for infrastructure and applications. We conduct weekly antivirus scanning of servers and workstations and regular penetration tests and security audits.
Our systems are hosted by a secure Tier 3/4 data centre provider and are backed up and tested regularly. Our data retention policy requires us to securely store backups for a minimum of 7 years Business continuity plans exist in each of our businesses.
Access to our systems is a role based model using least privileged principles, all users are provided with unique access ID’s and passwords that are changed regularly. We monitor and routinely check access control lists for accuracy and appropriateness.
We take the security our customer data very seriously, it is never shared with any 3rd parties and only used appropriately.

10. Your rights as a data subject

As a data subject whose personal data we hold, you have certain rights. If you wish to exercise any of these rights, please use the information supplied in the Contact Us section below. To process your request, we will ask you to provide a valid form of identification for verification purposes. Your rights are as follows:

The right to be informed
As a Data Controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice/policy and any related communications we may send you.

The right of access (also known as a ‘data subject access request’)
You have the right to request a copy of the personal data we hold about you (or having it transferred to another organisation) free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you, how we are using it, who we are sharing it with and how we obtained your data.

The right to rectification
You have the right to ask us to rectify or correct any of your personal data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete. This may be used with the right to restrict processing to make sure that incorrect/incomplete data is not processed until it is corrected/complete.

The right to erasure (the ‘right to be forgotten’)
You have the right to request that we erase/delete your personal data in certain circumstances, for example where no overriding legal basis or legitimate reason continues to exist for processing personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

The right to restrict processing
You have the right to ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure.

The right to data portability
You have the right to request your set of personal data be transferred to another Data Controller or Processor, provided in a commonly used and machine-readable format. This right only applies to data you have given us, the original processing was on the basis of consent/explicit consent/fulfilment of a contractual obligation and the processing is by automated means (is held electronically).

The right to object
You have the right to object to our processing of your personal data where:
a) Processing is based on legitimate interest (including profiling);
b) Processing is for the purpose of direct marketing; or
c) Processing is for the purpose of a task carried out in the public interest.

The right to withdraw consent
In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Right to human intervention
If the personal data is being used to make automated decisions about you as the data subject (e.g. profiling), to be told what logic the system uses to make those decisions and to be able to request human intervention to override any such automated decisions.

11. Do you have to provide your personal data to us?

You are never required to provide personal data to us, but you may need to do so when you enter into a contract for the provision of our services or products. We will not be able to provide our services or products unless you provide us with the personal data, we need to do so.

In addition, you will be required to provide certain personal data if you contact us to exercise your rights under GDPR as set out in section 10.

12. Automated decision-making and Cookies

We may carry out automated decision-making when you use our website. The automated decision making involves providing content to you based on your online behaviour obtained using Cookies. If consent is given for Cookies which are more than those required for essential use of the website, we will be able to display content that is relevant to you. Please refer to paragraph 14 below.

You can adjust cookies through the cookie preference settings.

13. Do we use your personal data for marketing?

Yes, we may use your personal data to carry out marketing within the Bunzl group of companies. We will only contact people who want to receive marketing as well as for our own legitimate interests. If you object to marketing, whether electronic or otherwise, please let us know and we will stop contacting you for marketing. We may still need to contact you for the purposes of providing services and products.

14. Cookies consent management

We use cookies, which are small text files placed on your computer by websites that you visit, to make our website work properly, to monitor its usage and to display content that we believe will be relevant to you. If you register with us or if you continue to use our site, we may ask if we can collect additional data from you automatically through cookies or similar technology. You will be asked to agree to our use of them through our cookie consent tool.

You can also block cookies by adjusting your browser settings. However, if you choose to block all cookies you may not be able to access all, or parts, of our site and some features will not work properly.

15. Contact us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to privacy-brhs@bunzl.co.uk.

Alternatively, you can contact us at the following postal address for our registered office:

GDPR Privacy Champion
c/o Daniel Roberts
Bunzl Woodway, Maynard Road,
Burton Latimer, Northamptonshire, NN15 5ZS

16. Complaints

We have appointed a Data Protection Privacy Champion to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact us. If you have any concerns about our use of your personal data, we would like the opportunity to respond to your concerns. You can make a complaint to us using the contact details above.

You have the right to contact the Information Commissioner’s Office (ICO) if you are unhappy with our response to your concerns. The ICO is the independent regulatory office dealing with the Data Protection Act 2018 and the General Data Protection Regulation across the UK

The ICO’s address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113 ICO website: https://ico.org.uk/global/contact-us/

Bunzl UK is incorporated in the UK, outside the EU, so we have appointed Bunzl Ireland Limited as our representative for the purposes of the GDPR compliance, and to deal with any supervisory authorities or data subjects in this respect at the following address:

Bunzl Ireland Limited (Co ref 662881), Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland.

17. Changes to this privacy notice

We reserve the right to update this privacy notice at any time; this policy was last updated February 2023.

BUNZL UK LIMITED
Company number 02902454
ICO reg. Z6549777

BUNZL IRELAND LIMITED
Company number IE114401