LEGAL
PRIVACY POLICY
Falfish Ltd are committed to protecting and respecting your privacy and personal data. This privacy and cookie policy relates to our use of any personal data we collect from you either via our website or direct.
As well as this Privacy Policy, your privacy is protected by law. The General Data Protection Regulation (‘GDPR’) that comes in to force on 25th May 2018 ensures that we use your personal information only if we have a proper reason to do so. This includes sharing it outside of Falfish Ltd.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.falfish.com you are accepting and consenting to the practices described in this policy.
GENERAL PRINCIPLES
We will only collect and use your information where we have lawful grounds and legitimate business reasons to do so
We will be transparent in our dealings with you and will tell you about how we will collect and use your information
If we have collected your information for a particular purpose we will not use it for anything else unless you have been informed and, where relevant, your permission obtained
We will not ask for more information than we need for the purposes for which we are collecting it
We will update our records when you inform us that your details have changed
We will continue to review and assess the quality of our information
We will implement and adhere to information retention policies relating to your information and will ensure that your information is securely disposed of at the end of the appropriate retention period
We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with
We will train our staff on their privacy obligations
We will ensure we have appropriate physical and technological security measures to protect your information regardless of where it is held
We will ensure that when we outsource any processes we ensure the supplier has appropriate security measures in place and will contractually require them to comply with these Privacy Principles
We will ensure that suitable safeguards are in place before personal information is transferred to other countries
DATA WE COLLECT ABOUT YOU
We may collect certain information or data about you when you contact us or use www.falfish.com, such as.
Questions, queries or feedback you leave, including your email address if you contact Falfish Ltd.
Your IP address, and details of which version of web browser you used
Information on how you use the site, using cookies and page tagging techniques
We may also collect personal data from you by communications, including email, telephone, post or social media, by networking and by engagement of services/provision of goods. This may include your (or your employer’s or our customers’) name, address, email address, date of birth, family relationships, bank account and payroll information.
We may also require documentary details from you such as driving licence, passport or birth certificate, in order to comply with our obligations under identification, money laundering and anti-terrorism legislation.
This data can be viewed by authorised people within Falfish Ltd to:
Improve the website by monitoring how you use it
Gather feedback to improve our services
Respond to any feedback you send us, if you’ve asked us to
Provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or by Legitimate Interests
Notify you about changes to our business, goods or services
Use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings
Enable us to invoice you for goods and services
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
THE LEGAL BASIS USED FOR PROCESSING YOUR DATA
The law says that we must have one or more of the following reasons for using your data:
To fulfil a contract we have with you to provide our services
Where it is our legal duty
When it is in our legitimate interest
When you consent to the use of the data
A legitimate interest is when we have a business or commercial reason to use your information. Even then, it must not unfairly go against what is right and best for you.
The legitimate interests that we will rely upon to process this information are:
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
To allow you to participate in interactive features of our service, when you choose to do so;
As part of our efforts to keep our site safe and secure;
To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
To maintain contact with you when you are an existing client outside of our contractual obligations.
WHERE YOUR DATA IS STORED
We store your data on secure servers in the European Economic Area (EEA).
By submitting your personal data, you agree to this.
HOW LONG DO WE RETAIN YOUR DATA
We will only retain your personal data for as long is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
The requirements of our business and the services provided;
Any statutory or legal obligations;
The purposes for which we originally collected the personal data;
The lawful grounds on which we based our processing;
The types of personal data we have collected;
The amount and categories of your personal data; and
Whether the purpose of the processing could reasonably be fulfilled by other means.
KEEPING YOUR DATA SECURE
Sending information over the internet is generally not completely secure, and we can’t guarantee the security of your data while it’s in transit. Any data you send is at your own risk.
We have robust procedures and security features compliant with the GDPR in place to keep your data secure once we receive it. 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.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DISCLOSING YOUR INFORMATION
We may pass on your personal information if we have a legal obligation to do so, or if we must enforce or apply our terms of use and other agreements. This includes exchanging information with other government departments for legal reasons.
We won’t share your information with any other organisations for marketing, market research or commercial purposes, and we don’t pass on your details to other websites.
YOUR RIGHTS
You can find out what information we hold about you and ask us not to use any of the information we collect.
A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to the contact details provided in this policy. If we do hold any of your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
The information we supply will:
Confirm that your data is being processed;
Verify the lawfulness and the purpose of the processing;
Confirm the categories of personal data being processed;
Confirm the type of recipient to whom the personal data have been or will be disclosed; and
Let you have a copy of the data in an intelligible form.
Please note that you may need to provide identification in order to prove who you are to access your data.
In the instance that we do not hold personal information about you we will also confirm this in writing within one calendar month.
To discuss our privacy policy or your individual rights you can contact us at the address below.
LINKS TO OTHER WEBSITES
www.falfish.com contains links to other websites.
This privacy policy only applies to www.falfish.com,and doesn’t cover other services that we link to. These services have their own terms and conditions and privacy policies.
Following a link to another website:
If you go to another website from this one, read the privacy policy on that website to find out what it does with your information.
Following a link to www.falfish.com from another website:
If you come to www.falfish.com from another website, we may receive information from the other website. We don’t use this data. You should read the privacy policy of the website you came from to find out more about this.
CONCERNS OR COMPLAINTS
If you have any complaints in relation to how our business has processed your data or in relation to the exercise of your rights as detailed above you can, in the first instance, raise your concerns by contacting us at the following address: Falfish Ltd, 15 Cardrew Industrial Estate, Redruth, Cornwall, TR15 1SS.
You may also contact the Information Commissioner’s Office in relation to any such complaints. https://ico.org.uk/concerns
MODERN SLAVERY STATEMENT
INTRODUCTION
This is a statement under s.54 of the Modern Slavery Act 2015. It relates to the business of Falfish (Holdings) Limited and its subsidiary Falfish Limited (together referred to as “Falfish”).
We are committed to improving our practices to combat slavery and human trafficking. This statement sets out Falfish’s actions to understand all potential modern slavery risks related to the business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in the business and our supply chains.
As part of the fishing sector, Falfish recognise that we have a responsibility to take a robust approach to slavery and human trafficking. The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
OUR BUSINESS AND ORGANISATIONAL STRUCTURE
Falfish supplies fish to customers throughout the United Kingdom and Europe, controlled from its Head Office in Redruth, Cornwall. We have over 150 employees, all of which are recruited through the Company’s Head Office, which also sources any sub-contractors when required. Due to the seasonal nature of the business operation, we engage a number of temporary staff through employment agencies which averages 35 people per month during a 12 month period.
OUR SUPPLY CHAINS
Suppliers providing goods and services to the Company are predominately based in the United Kingdom or Europe. Global suppliers can be used on occasion as necessary.
Falfish operates a supplier policy and maintains a preferred supplier list. We endeavour to build long term relationships with key suppliers, and all procurement is subject to the relevant criteria being satisfied prior to engagement. We complete due diligence checks on all suppliers prior allowing them to become a preferred supplier, including an online search if necessary to ensure that the particular organisation has never been convicted of offences relating to modern slavery.
In addition to the above, as part of the Company’s contract with suppliers, the supplier is required to confirm
that:
1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account over modern slavery.
3. They pay their employees at least the national minimum wage / national living wage where applicable.
4. The Company may terminate the contract at any time should concerns in relation to modern slavery arise.
OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING
The Company operates the following policies that describe its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:
• Modern Slavery – The Company is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
• Whistleblowing – The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Valuing Dignity and Diversity at Work – The Company’s Valuing Dignity and Diversity at Work policy makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
• Equal Opportunities – The Company promotes the right for all workers, customers and other business partners to be treated without discrimination, especially on the grounds of protected characteristics.
• Bribery – The Company is committed to ensuring adherence to the highest level of ethical standards.
• Supplier Code of Conduct – The Company is committed to selecting suppliers who are known to adhere to the highest standards of ethics, treat workers with dignity and respect, and act ethically and within the law in their use of labour. However, any serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency Workers – The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
DUE DILIGENCE PROCESSES FOR MODERN SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
The Company is subject to Ethical Audits with certain suppliers which demonstrates compliance and commitment on behalf of Falfish when working with our supply chain.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics, we have in place certain supply chain compliance programmes.
This includes Gangmaster Licencing audits for all recruitment / employment agencies on a six-monthly basis. Failure to meet the criteria may result in Falfish terminating the business relationship with the recruitment / employment agency.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
The Company conducts training for its procurement / buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within the Company’s supply chain.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will continue to build on the progress we have made this year. We will continue to improve communication on this topic with our supply chain and welcome opportunities to collaborate with suppliers. We routinely monitor our staff and agency providers to ensure we are complying with the Modern Slavery Act 2015. This is done via external audits and measures compliance.
BOARD APPROVAL
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending March 2021.
This statement has been approved by the Company’s board of directors who will review and update it annually.
Managing Directors Signature:
Mark Greet
Date: 31st March 2020