Privacy Policy

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to The Furniture Practice Ltd collecting/processing their personal data.

2.2 All Employees of The Furniture Practice Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

The Furniture Practice is an independent furniture company that strives to be the most caring, innovative and effective furniture company with the world’s best supply chain. With excellent relationships with over 450 manufacturers and over 20 years of experience delivering projects of all sizes we are able to offer a truly objective, design- led service.

Our Data Protection Officer and data protection representatives can be contacted directly here:

• Data.protection@thefurniturepractice.com
• 020 7549 5454

The personal data we would like to collect, and process is:
Personal data type / Source (where The Furniture Practice Ltd obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources):

Name / Obtained directly with implicit permission
Email Address / Obtained directly with implicit permission
Phone Number / Obtained directly with implicit permission
Passport Details & Image of passport / Obtained directly with implicit permission

The personal data we collect will be used for the following purposes:

• Marketing and information communication purposes
• Assisting in the commission of travel plans in relation to our business

Our legal basis for processing for the personal data:

• Explicit Consent

Any legitimate interests pursued by us, or third parties we use, are as follows:

• Explicit Consent to Marketing and information communications
• Details required for the booking of travel arrangements in regard to our business activities

The special categories of personal data concerned are:

• None taken (no biometric data is taken from passport)

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for The Furniture Practice Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by emailing the DPO on data.protection@thefurniturepractice.com with the attached form GDPR Rec 4.6a as per internal policy GDPR DOC 2.7A.

3.3 Disclosure

The Furniture Practice Ltd will pass on your personal data to third parties as required to complete our duties. Microsoft Office 365, Proofpoint, and Mailchimp are used for only communications (both marketing and direct communications regarding travel or company services). Box.com is used as The Furniture Practice’s secure cloud storage provider. Netsuite is used only for the CRM information storage. Various travel agencies/organisations can be used in the booking of travel as required for company travel(These vary and can be disclosed as required)

Third country (non- EU)/international organisation / Safeguards in place to protect your personal data / Retrieve a copy of the safeguards in place here:

Organisation Name & geographic location
Box.com / All data is secured via industry standard security and Privacy Shield. This data is completely encrypted. / https://www.box.com/en-gb/legal/privacypolicy

Microsoft Office 365 / All data is secured via industry standard security and Privacy Shield. Used only for Email communications, personal data if required to be sent is done via secure link with Box.com / https://privacy.microsoft.com/en-gb/privacystatement

Mailchimp / All data is secured via industry standard security and Privacy Shield. Used only for Email communications. / https://mailchimp.com/help/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr/

Proofpoint Essentials (USA) / All communications encrypted and with secured admin only access. Poofpoint is a member of Privacy Shield. For the purpose of email security only. / https://www.proofpoint.com/us/privacy-policy

Netsuite / All data is secured via industry standard security and Privacy Shield. This data is completely encrypted. / http://www.netsuite.com/portal/privacy.shtml

Various Travel Organisations / All information is only sent via secure passworded Box.com links. For the purpose of travel booking only. / Can be requested at time of consented travel booking from data.protection@thefurniturepractice.com as partners used may change.

3.4 Retention period

The Furniture Practice Ltd will process and store the personal data for a maximum of 3 months following an organized trip or until a request to opt out is received for marketing information. Refer to GDPR DOC 2.3 internally.

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the
right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that The Furniture Practice Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by The Furniture Practice Ltd (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and The Furniture Practice Ltd’s data protection representatives Data Protection Officer.

The details for each of these contacts are:

Supervisory authority contact details / Data Protection Officer (DPO) contact details

Contact Name: Information Commissioner’s Office / Fredrika Juhlin
Address line 1: Wycliffe House / 31 Pear Tree Street
Address line 2: Water Lane, Wilmslow / London
Address line 3: Cheshire / EC1V 3AG
Address line 4: SK9 5AF
Address line 5: UK / UK
Email: https://ico.org.uk/concerns/handling/ / Data.protection@thefuniturepractice.com
Telephone: 0303 123 1113 / 020 7549 5454

3.7 Privacy statement

Read more about how and why we use your data here or read below.

4. Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy notice tells you how we, The Furniture Practice Ltd, will collect and use your personal data for marketing and information communication purposes, for the legitimate purpose of conducting our business and contracts and for the booking of travel as required for that business.

Why does The Furniture Practice Ltd need to collect and store personal data?

In order for us to provide you with information or aspects of our service we need to collect personal data for correspondence purposes, Marketing information and travel booking. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes The Furniture Practice Ltd would contact you for additional consent.

Will The Furniture Practice Ltd share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to The Furniture Practice Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with The Furniture Practice Ltd’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will The Furniture Practice Ltd use the personal data it collects about me?

The Furniture Practice Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. The Furniture Practice Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will The Furniture Practice Ltd contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

The Furniture Practice Ltd at your request, can confirm what information we hold about you and how it is processed. If The Furniture Practice Ltd does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined
how and why to process your data. In some cases, this will be a representative in
the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of The Furniture Practice Ltd
or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and
any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

The Furniture Practice Ltd accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months)

Contact details of the Data Protection Officer:

Data Protection Officer / GDPR Owner contact details

Contact Name: Fredrika Juhlin
Address line 1: 31 Pear Tree street
Address line 2: London
Address line 3: EC1V 3AG
Address line 4:
Address line 5: UK
Email: Data.protection@thefurniturepractice.com
Telephone: 020 7549 5454

Document Owner and Approval

The Data Protection Officer / GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff on Box.com

Change History Record

Issue: 1
Description of Change: Initial Issue
Approval: Mark Nicol
Date of Issue: 11 May 2018