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GDPR / Data Protection Policy

Terms & Conditions | Data Protection | Privacy Policy | Cookie Policy | Disclosure

 

 

The EU General Data Protection Regulation (GDPR) came into effect May 25, 2018

The regulation is a positive step towards giving you more control over how your data is used online and off.

Bullion.Directory is committed to making our use of your data as transparent as we can – this page tells you who we are, how we collect your data, what we do with it and how you can access, change or delete any data we hold.

Bullion.Directory / Tartan Digital Limited is registered with the Information Commissioner’s Office – Ref. ZA063131

We are a UK-registered “Data Collector” under the GDPR for EU data collection.
To view our current ICO certification, please select document:   ICO Certificate pdf | ICO Entry Details pdf

Bullion.Directory is a trading style of Tartan Digital Limited, a UK Registered Limited Company #SC253475
Registered Offices: 106B High Street, Dunbar EH42 1JJ, UK

How GDPR impacts your use of this site and how we collect and use your data along with your rights to access this data or to have your data deleted is noted in the following sections – General Site and Database Security, Your Data on Our Site and our Data Protection Policy Statement.

General Site and Database Security

The security of your data is of utmost importance to us, as is providing a secure service free from malware, spyware or any other issues.

Our web server and email servers are running a hardened firewall and our site runs behind an SSL (Secure Sockets Layer) connection with all traffic passing an additional robust on-site firewall, IP check and bot-blocker to increase overall site security, reduce site attacks and restrict or disallow traffic from certain higher-risk locations. All emails are sent and received by secure protocol.

Our site database and all email data is contained on this firewall-protected and encrypted server. The database is backed up regularly to a secure local drive, held offline in a secure location using an encrypted database behind a strong password-protected interface.

All files on our server are scanned daily for security risks, malware and unauthorised access.

Only key members of our staff have any access to our server or admin-level access to the bullion.directory site.

In the unlikely event of unauthorised site access, or any breach concerning your personal data we will notify you within 42 hours.

Your Data on Our Site

The personal data we store is collected through several on-site forms and by direct email. How each form and submission is handled by us is detailed as follows:

A. Comments on Articles
Commenting on published articles will involve submitting a name and e-mail address along with your comment.

We do not check the validity of this given name or email address. When commenting the security software running on our site will take note of the IP address from where you have submitted your comment along with the date and time of the comment. The only submitted data shown to the public will be your name and your comment as submitted along with the date of submission. Your IP address, time of submission and your email are held in our secure database and are not used for any purpose other than record-keeping – unless requested by a legal authority in the UK.

If you have submitted a comment, you may request a copy of the data we hold on you, request a comment be removed or amended, or request all data we hold on you be deleted by writing to our Data Protection Compliance Manager (see below). We aim to comply within two working days.

B. Reviews on Listings
Reviewing and rating a company listed in our directory will involve submitting a name and e-mail address along with your review and a rating.

We do not check the validity of this given name or email address. We do make a decision as to whether the review is legitimate. When reviewing and rating a listing the security software running on our site will take note of the IP address from where you have submitted your review along with the date and time of the comment. This will help us assess if we feel the review is legitimate. If we do publish the review, the only submitted data shown to the public will be your name, your review and rating as submitted along with the date of submission. Your IP address, time of submission and your email are held in our secure database and are not used for any purpose other than record-keeping – unless requested by a legal authority in the UK. Reviews we feel are not legitimate are deleted along with all connected data.

If you have submitted a review, you may request a copy of the data we hold on you, request a review be removed or amended , or request all data we hold on you be deleted by writing to our Data Protection Compliance Manager (see below). We aim to comply within two working days.

C. Adding a Listing
Requesting a company be listed in our directory is a commercial solicitation involving commercial data – that is it should use a company-given email, be submitted by an employee of the company concerned and sent from a company location.

As such commercial listing requests contain non-personal data and should fall outside of GDPR – however we handle submitted data with the same care as personal data and will never disclose the name or email of the person submitting the form to third parties.

D. Newsletter Subscribers
Requesting a subscription to our free newsletter service will generate an automatic welcome email and add the name and email you supply to our database of subscribers.

We will only use your submitted data in relation to supplying you with our monthly newsletter and special offers and to select a winner in our monthly subscriber draw. We do not use subscriber submitted data for any other purpose, or share this data with third parties, unless permission has been explicitly given to do so.

You may request to be removed from our subscriber list at any time and that we delete your subscriber data by writing to our Data Protection Compliance Manager (see below).

E. Email Form Submissions
Contacting us via our email contact form will generate an email held on our secure email server.

We will respond to your email if required and will only use your submitted data in relation to responding to the content of your email. We do not use the emails we hold from these submissions for any other purpose and do not create an email list, or share email data with third parties.

You may request we delete your email/s by writing to our Data Protection Compliance Manager (see below).

F. Direct Emails
Contacting us via a direct email, will lead to your email being held on our secure email server.

We will respond to your email if required and will only use your submitted data in relation to responding to the content of your email. We do not use the emails we hold from these submissions for any other purpose and do not create an email list, or share email data with third parties.

You may request we delete your email/s by writing to our Data Protection Compliance Manager (see below).

G. Free Guide / Information Requests
We work with trusted third parties who supply our visitors with free guides, books, PDFs, DVDs and other information products on submission of limited personal data. This data will typically include a name, email address and telephone number.

Our handling of this data is strictly limited to collecting the information through the form displayed on the user’s browser. This data is immediately sent to the company providing the information in order for the company to fulfill the request. We do not hold, have access to, or process this data at any time.

Because we will only work with companies we know to have robust data protection policies in place and who we believe to be in full compliance with GDPR – any personal data submitted through these information requests will be carried out in full compliance with the regulations.

H. Prize Draws
We run an annual prize draw as part of our Bullion Dealer of the Year Awards, as well as a Monthly Subscriber Draw – and in order to process entries, we collect name, email and country location on any related entry forms, or as part of the subscription application process.

We do not check the validity of any given name or email address. When submitting an entry for our Bullion Dealer of the Year Prize Draw, the security software running on our site will take note of the IP address from where you have submitted your entry along with the date and time of the comment. No data will be shown to the public. Your Name, IP address, time of submission and your email are held in our secure database and are not used for any purpose other than running the prize draw.

We do not make any further use of this information and do not share it with third parties. All non-subscriber prize draw entry data is deleted after 1 year.

If you have submitted an entry, you may request a copy of the data we hold on you, request your entry be removed or request all data we hold on you be deleted by writing to our Data Protection Compliance Manager (see below). We aim to comply within two working days.

I. Other Data
In browsing our website, we set small files on your computer called cookies – these are described in our Cookie Policy and help with the function of the site, setting user preferences and displaying content to you based on your preferences.

Some of these cookies will belong to third parties. On bullion.directory these third parties are advertising networks such as Google AdSense, analytics services such as Google Analytics and video service providers such as YouTube.

Our server makes a note of your IP address whilst browsing pages, as part of our site security.

In normal situations, this will be discarded within 7 days, however if your IP address is associated with threatening or suspicious behaviour we may add this IP address to a list of banned IP addresses meaning you no longer have access to our services.

J. Other Data Controllers
We may make use of third party services, such as working in partnership with companies providing our users with free books and DVDs, or with companies who run our annual Bullion Dealer of the Year public vote.

When we do so, we will seek to ensure they are also compliant with GDPR before using their service to ensure that any data transferred will be at least as secure as data we control.

Data Protection Policy Statement

1.1 Everyone has rights with regard to how their personal information is handled. During the course of our activities we may collect, store and process personal information about our visitors, customers and staff, and we recognise the need to treat it in an appropriate and lawful manner.

1.2 The types of information that we may be required to handle include details of current, past and prospective employees, suppliers, customers, visitors who provide us with information as part of our commenting or review process and others that we communicate with. The information, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 2018 (the Act), GDPR and other regulations. These acts and regulations impose restrictions on how we may collect, access and use that information.

1.3 This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action.
 

Status of the policy

1.4 This policy sets out our rules on data protection and the legal conditions that must be satisfied in relation to the obtaining, handling, processing, storage, transportation and destruction of personal information.

1.5 The Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. That post is held by Alan Macallister (alan@tartan.digital). Any questions or concerns about the operation of this policy should be referred in the first instance to the Data Protection Compliance Manager.

1.6 If you consider that the policy has not been followed in respect of personal data about yourself or others you should raise the matter with your line manager or the Data Protection Compliance Manager.
 

Definition of data protection terms

1.7 Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

1.8 Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident or EU national or resident. All data subjects have legal rights in relation to their personal data.

1.9 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as an email, name, address or date of birth) or it can be an opinion (such as a performance appraisal or personal views regarding a company listed in our directory).

1.10 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. We are the data controller of all personal data used in our business.

1.11 Data users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following our data protection and security policies at all times.

1.12 Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.

1.13 Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing may also include transferring personal data to third parties, but to do so will require additional approval from the subject of that personal data.

1.14 We do not collect sensitive personal data including information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings.
 

Data protection principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:
(a) Processed fairly and lawfully.
(b) Processed for limited purposes and in an appropriate way.
(c) Adequate, relevant and not excessive for the purpose.
(d) Accurate.
(e) Not kept longer than necessary for the purpose.
(f) Processed in line with data subjects’ rights.
(g) Secure.
(h) Not transferred to people or organisations situated in countries without adequate protection.
 

Fair and lawful processing

1.15 The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case Alan Macallister), who the data controller’s representative is (in this case the Data Protection Compliance Manager), the purpose for which the data is to be processed by us, and the identities of anyone to whom the data may be disclosed or transferred.

1.16 For personal data to be processed lawfully, certain conditions have to be met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed.
 

Processing for limited purposes

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose and agree to this new purpose before any processing occurs.
 

Adequate, relevant and non-excessive processing

Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.
 

Accurate data

Personal data must be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed.
 

Timely processing

Personal data should not be kept longer than is necessary for the purpose. This means that data should be destroyed or erased from our systems when it is no longer required.
 

Processing in line with data subject’s rights

Data must be processed in line with data subjects’ rights. Data subjects have a right to:
(a) Request access to any data held about them by a data controller.
(b) Prevent the processing of their data for direct-marketing purposes.
(c) Ask to have inaccurate data amended.
(d) Ask to have all data removed under the “Right to be Forgotten”
(d) Prevent processing that is likely to cause damage or distress to themselves or anyone else.
 

Data security

1.17 We must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. Data subjects may apply to the courts for compensation if they have suffered damage from such a loss.

1.18 The Act requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

1.19 Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:
(a) Confidentiality means that only people who are authorised to use the data can access it.
(b) Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on our central computer system instead of individual PCs.

1.20 Security procedures include:
(a) Entry controls. Any stranger seen in entry-controlled areas should be reported.
(b) Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
(c) Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required.
(d) Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
 

Dealing with subject access requests

A formal request from a data subject for information that we hold about them, or to have this information deleted should be made in writing. There is no fee payable by the data subject for provision of this information or the deletion of their information. Deletion will be permanent. Any member of staff who receives a written request should forward it to Alan Macallister immediately.
 

Providing information over the telephone

Any member of staff dealing with telephone enquiries should be careful about disclosing any personal information held by us. In particular they should:
(e) Check the caller’s identity to make sure that information is only given to a person who is entitled to it.
(f) Suggest that the caller put their request in writing if they are not sure about the caller’s identity and where their identity cannot be checked.
(g) Refer to Alan Macallister for assistance in difficult situations. No-one should be bullied into disclosing personal information. Disclosure of personal information to someone to whom disclosure should not be made is a crime and if there is any doubt as to the legitimacy of a request our staff will not disclose.
 

Monitoring and review of the policy

1.21 This policy is reviewed monthly by our board of directors. Recommendations for any amendments are reported to the entire Bullion.Directory workforce.

1.22 We will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives.

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