Happy Days Beachfield and Happy Days Seaside Privacy Notice

1. Statement of policy

Happy Days Beachfield and Seaside (thereafter called Happy Days) are fully committed to compliance with the requirements of the General Data Protection Regulation (GDPR), Data Protection Act 1998 and any successor legislation (together, the ‘data protection legislation’) Happy Days is committed to a policy of protecting the rights and freedoms of individuals with respect to the processing of their personal data.

Happy Days will therefore follow procedures which aim to ensure that all employees, and others who have access to any personal data held by or on behalf of Happy Days, are fully aware of and responsible for the handling of personal data in line with the data protection legislation.

In order to operate efficiently, Happy Days has to collect and use information about people with whom it works. These may include current, past and prospective clients; current, past and prospective employees; our caravan owners and our suppliers.

Data protection legislation and in particular Article 5 (1) of the GDPR requires that personal data shall be used in accordance with the following principles:

a) processed lawfully, fairly and in a transparent manner in relation to individuals;

b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

Article 5 (2) of the GDPR requires that:

“the controller shall be responsible for, and be able to demonstrate, compliance with the principles.” Lawful basis for processing personal data under the data protection legislation

Happy Days primarily uses consent as the lawful basis for processing personal data.

Happy Days also process personal data under the following lawful bases:

We process personal information to enable us to promote our goods and services, to maintain our accounts and records and to support and manage our staff.

2. Handling of personal data

Happy Days will, through appropriate management and the use of appropriate controls adhere to the following in regards to our use of personal data and special category personal data;

Provide up to data privacy notices to data subjects.
Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with legal requirements.
Ensure the quality and accuracy of information when collected or received and during its use.
Apply checks to determine the length of time information is retained.
Take appropriate technical and organisational security measures based on risks to data subjects.
Not transfer outside the EEA without suitable safeguards.
Ensure that any information incidents are reported to the Information Commissioners Office.
Mitigate risks to the data subjects in the event of an information incident using an appropriate data breach policy.
Ensure that the rights of our data subjects can be properly exercised.

These rights include:

The right to be informed
The right of access
The right to rectification
The right to erase
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling

In addition, we will ensure that:

There is someone with specific responsibility for data protection in the organisation. The post responsible for data protection is Melanie Watson
Organisational information and in particular privacy risks are risk assessed, documented and controlled.
Everyone managing and handling personal data and special category personal data understands that they are responsible for following good Information Governance / Assurance practice and for complying with the data protection legislation.
Everyone managing and handling personal data is appropriately trained and supervised to do so.
Queries about processing personal are promptly and courteously dealt with within the requirements of the data protection legislation.
Data sharing and processing is carried out under an appropriate written agreement, setting out the scope and limits of the sharing. Any disclosure of personal data will be in compliance with approved procedures.

All employees are to be made fully aware of this policy and their duties and responsibilities under it. All employees will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure.

3. Data management systems

Happy Days Beachfield and Happy Days Seaside are joint data controllers for the personal data within the storage of data and therefore each have a joint responsibility to ensure compliance with data protection legislation.

Our computer storage is used to process information, personal data provided by caravan owners and employees in the course of working for Happy Days or owning a caravan or advertising holidays.

All information, personal data is to be regarded as being confidential between the individual and the Happy Days unless expressly indicated otherwise.

In all cases the relevant consent must be obtained, or alternative lawful basis determined, for any processing or sharing of personal data.

Where necessary or required we shall share data with.

Family associates and representatives of the person whose personal data we are processing
Employment and recruitment agencies
Current, past and prospective employers
Educators and examining bodies
Central Government
Credit reference agencies
Suppliers and Service providers
Debt collection and tracing agencies
Financial organisations

CCTV for crime prevention

CCTV is used for maintaining the security of property and premises and for preventing and investigating crime. It may also be used to monitor staff when carrying out work duties. For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about staff, customers and clients, offenders and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance. Where necessary or required this information is shared with the data subjects themselves, employees and agents, services providers, police forces, security organisations and persons making an enquiry.