For the purpose of the Data Protection Act 1998 ("the Act"), the data controllers are Holiday Cottage Compare Limited of 94 Coventry Road, Market Harborough, Leicestershire, LE16 9DA, UK. We are registered under the Data Protection Act 1998, number Z3301661.
In general, we use the information we collect about you to help property owners or agents placing advertisements (an "Advertiser") to provide accommodation solutions to users of our site (a "Holidaymaker").
In particular, when you proceed to book a property from our site, we will transfer your details to the Advertiser you are booking with, in order that you can complete your booking with them.
We also use the information we collect about you to improve the features and services we offer and to support our own marketing and promotion efforts.
We will not disclose any personally identifiable information without your permission unless:
- We are legally entitled to do so (for example, pursuant to a court order or for the purposes of prevention of crime or fraud). You will be treated as having given your permission for disclosures referred to in this policy.
- We are in negotiations with a third party for the sale or purchase of any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- We, or substantially all of our assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
When you visit, register or use the services on our site, you may be asked to provide certain information about yourself, including your name and your contact details. We may also collect information about your use of our site as well as information about you from the emails or letters sent by you. We may collate this information to identify patterns which we can use in our marketing and to help us develop, administer, support and improve our services and features.
In particular, we may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to our site or our services. Further, where you have consented, we might also use your information to email you with details about any other products or services which we offer which may be of interest to you. If you change your mind about being contacted in the future, please email us.
We aim to keep our records as accurate as possible. If you would like to review or change the details that you have supplied us with at any time, you can either amend your details directly by going to the 'My HolidayCottageCompare' section of the website, or by contacting us using the details below.
The technology that we use and the policies that we have implemented are intended to safeguard your privacy from unauthorised access and improper use. We will continue to update these measures as new technology becomes available.
Access to Information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
What are cookies?
Cookies are text files that are stored by a website’s server on your computer or mobile device. Cookies, by themselves, do not identify the individual user and do not harm your system. Cookies allow a website to remember things like your preferences - or what’s in your list of saved cottages.
Cookies have a variety of functions, such as storing your preferences; allowing you to navigate between pages effectively and improving your overall experience of a website.
Without cookies, every time you navigate to a new page on a website, that site would think you were a new visitor.
Cookies may either be set by the website you are visiting (‘first party cookies’) or other websites who run content on the page you are viewing (‘third party cookies’).
Information supplied by cookies helps us to understand how our visitors use our website so that we can improve how we present our content to you.
Cookies may also be set by a third party company (third party cookies).
If you wish to restrict or block web browser cookies altogether, you can also do this through your browser settings. Or you can visit www.aboutcookies.org for further information about how to do this on a wide range of desktop browsers.
Restricting or blocking web browser cookies will however mean that you will lose some features and functionality of our website.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Changes to this policy
If you have any queries or comments about the policy or our use of your personal information, please email us at firstname.lastname@example.org or write to us at 94 Coventry Road, Market Harborough, Leicestershire, LE16 9DA, UK.
GDPR Compliance Statement
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
Holiday Cottage Compare Ltd are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the [UK’s Data Protection Bill].
Holiday Cottage Compare Ltd are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
Holiday Cottage Compare Ltd’s preparation includes: -
• Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
• Policies & Procedures - [revising/implementing new] data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
o Data Protection – our main policy and procedure document for data protection is being overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
o Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
o Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
o Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
• Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
• Privacy Notice/Policy – we are revising our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
• Obtaining Consent - we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via [our website, in the office, during induction etc] of an individual’s right to access any personal information that Holiday Cottage Compare Ltd processes about them and to request information about: -
• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from them, information about the source
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
Holiday Cottage Compare Ltd takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: - access controls, password policy, encryptions, practices, restriction, IT, authentication.
GDPR Roles and Employees
Holiday Cottage Compare Ltd have designated Paula Alexander as our [Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Holiday Cottage Compare Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our preparation for the GDPR, please contact our Data Protection Officer (DPO), Paula Alexander.