Dairy Crest Farm Connect Privacy Notice
 
1. Introduction

 
Welcome to Dairy Crest’s Farm Connect privacy notice.
 
We operate Farm Connect, our innovative farmer website, to provide you with data and information to help you manage your milk contract together with the latest news and information about Dairy Crest.
 
We hold personal data about you as a supplier of milk to Dairy Crest and may hold some data about your family business. This is needed for us to comply with the milk contract and our legal obligations. This privacy notice gives you an overview about how Dairy Crest (and anyone acting on our behalf) processes your personal data, the arrangements which are in place to protect it and how to find out more. This notice is for information – you do not need to take any action.
 
This notice will also tell you about your privacy rights and how the law protects you. 
 
2. Important information and who we are
 
Purpose of this privacy notice
 
This privacy notice aims to give you information on how Dairy Crest collects and processes your personal data provided in accordance with your milk contract with us and through your use of this website, including any data you may provide through this website.
 
Dairy Crest Limited is the controller and responsible for your personal data (referred to as “Dairy Crest”, "we", "us" or "our" in this privacy notice).
 
We have appointed a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, or if you require more detail about the legal bases for processing your personal data please contact the Data Privacy Manager using the details set out in paragraph 10 below.
 
Changes to the privacy notice and your duty to inform us of changes
 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 
Third-party links
 
The Farm Connect website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
 
3. The data we collect about you
 
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
 
• Identity Data including first name, last name, user name or similar identifier, title and gender.
 
• Contact Data including addresses, email address and telephone numbers.
 
• Farm Data including details of compliance with Davidstow Farm Standards and the Red Tractor Assurance Dairy Scheme including audit reports.
 
• Financial Data including bank account details.
 
• Health Data including details of your health and wellbeing, illness or injury.
 
• Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform and other technology on the devices you use to access the website.
 
• Usage Data includes information about how you use our website.
 
We may also aggregate and/or anonymise your personal data (so that it can no longer be associated with you) for statistical purposes in which case we may use this information indefinitely without further notice to you.
 
Apart from Health Data collected in accordance with this privacy notice, we do not knowingly collect any other special categories of personal data about you (including e.g. details about your race or ethnicity or criminal convictions).
 
If you fail to provide personal data
 
Where we need to collect personal data by law, or under the terms of the contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have. We will notify you if this is the case at the time. 
 
4. How is your personal data collected?
 
We collect data from and about you when you enter into a milk contract with us and when you contact a member of the Dairy Crest Farm Business Team by phone, post or email or via the
farm.business@dairycrest.co.uk email or Farm Connect website www.dcfarmconnect.co.uk.
 
How we use your personal data
 
We will only use your personal data when the law allows us to. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage the Milk Producer’s Agreement, including ensuring the milk meets the required standards and to keep you informed of updates and information relevant to your supply of milk, including payments and calculations (a) Identity
(b) Contact
(c) Farm
(d) Financial
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (for quality monitoring and improvements, to carry out an investigation, to take appropriate action and to provide a meaningful response, for the establishment, exercise or defence of legal claims).
To enable us and third party suppliers and partners to carry out audits, inspections and testing as and when considered necessary
To enable third parties to carry out technical, logistical or other functions on our behalf
(a) Identity
(b) Contact
(c) Farm
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (for quality monitoring and improvements, to carry out an investigation, to take appropriate action and to provide a meaningful response, for the establishment, exercise or defence of legal claims).
To manage our relationship with you which will include:
(a) Notifying you about changes to the Milk Producer’s Agreement and any other aspect of your supply of milk to us
(b) Notifying you about changes to the Farm Business Team
(c)
  Processing and dealing with complaints, comments and feedback
(d) Notifying you about changes to our privacy policy
(e) Maintaining internal records
(a) Identity
(b) Contact
(c) Farm
(d) Financial
(e) Health
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (for quality monitoring and improvements, to carry out an investigation, to take appropriate action and to provide a meaningful response, for the establishment, exercise or defence of legal claims)
To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website (a) Technical
(b) Usage
Necessary for our legitimate interests (to keep our website updated and relevant)

 
Generally we do not rely on consent as a legal basis for processing your personal data and we do not need your consent if we use special categories of your personal information in accordance with this policy to carry out our legal obligations.
In certain limited circumstances, we may also process other special category data with your explicit written consent or where you have already made the information public.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 
 
Change of purpose 
 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 
5. Data sharing
 
We may have to share your data with third parties, including third-party service providers.
 
We will only share your personal information with third parties where required by law or where we have another legitimate interest in doing so. The categories of third party with whom we share information are as follows:
 
• Hauliers, suppliers of milk testing, auditing and certification services and any other third party as advised to you from time to time
• The Food Standards Agency and/or such other government body as may be required from time to time
• Third party service providers who provide our IT software and systems
• Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers who provide ad hoc legal, auditing and insurance services
• Rarely, advisors and fraud prevention agencies acting as processors to provide fraud detection services
  All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
 
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
 
6. Transferring information outside the EEA
 
Some of our third party suppliers process personal data in countries outside the European Economic Area (“EEA”) such as the United States of America. As such, we will transfer your personal data to these countries in order to perform our contract with you. There is not an adequacy decision by the European Commission in respect of those countries. This means that the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.
 
However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:
 
(1) standard contractual clauses approved by the European Commission decision for the transfer of personal data to processors established in third countries from time to time; or
 
(2) when sending data to the United States of America, the US-EU Privacy Shield.
 
If you require further information about these protective measures, please contact the Data Privacy Manager.
 
7. Data security
 
We have put in place 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 employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
 
We have put in place procedures to deal with any suspected personal data breach and will notify you and the applicable regulator, the Information Commissioner’s Office (ICO), of a breach where we are legally required to do so.
 
8. Data retention
 
How long will you use my personal data for?
 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
 
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.
 
In most cases, we will keep your personal data for the duration of the milk contract and for a period of six (6) years after its termination.
 
9. Your legal rights
 
Under certain circumstances, by law you have the right to:
 
(1) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
 
(2) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
 
(3) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
 
(4) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
 
(5) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
 
(6) Request the transfer of your personal information to another party.
 
(7) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain information to you to help manage the milk contract. We will advise you if this is the case at the time you withdraw your consent.
 
In some circumstances there may be specific legal reasons why we are not able to comply with your request to exercise your rights. Where this is the case, we will inform you of this.
 
If you wish to exercise any of the rights set out above, please contact the Data Privacy Manager in writing.
 
You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
 
What we may need from you
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
Time limit to respond
 
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 
 
10. Data Privacy Manager
 
 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (
www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 
 

Full name of legal entity: Dairy Crest Limited

Contact: Data Privacy Manager

Email address: datacontroller@dairycrest.co.uk

Postal Address: Data Privacy Manager, Dairy Crest Limited, Claygate House, Littleworth Road, Esher, Surrey, KT10 9PN


11. Changes to this privacy notice
We reserve the right to make changes to this privacy notice at any time.
This version was last updated on 3 July 2018.
If you have any questions about this privacy notice, please contact the Data Privacy Manager at
datacontroller@dairycrest.co.uk