Policies

Overall responsibility for health and safety and for approving and reviewing our Health and Safety Policy lies with the Gooch & Housego PLC Board which has determined that: It is policy to ensure, so far as is reasonably practicable, the health, safety and welfare of all our employees and visitors.

This policy statement applies to all G&H Group locations and activities. The responsibility for its implementation jointly rests with our line management and with each employee.

Managing health and safety is a key priority and is an integral part of managing the total risks faced by our business. G&H operates a global Group Risk Management process and review process which incorporates health and safety. The Board will also receive regular updates on health and safety.

G&H is committed to reducing our environmental impact and continually improving our environmental performance as an integral and fundamental part of our business strategy and operating methods. G&H aim to reduce the environmental impacts of all our activities and to help
our customers, suppliers and partners to do the same as a matter of delivering on our duty of care towards future generations.

G&H policy is to promote the adoption of a standardized approach and this policy is based on the international standard ISO 14001 Environmental management system in conjunction with ISO 14004 General guidelines on principles, systems and support techniques. ISO 14004 provides further guidelines for the elements of an EMS and its implementation.

G&H will review and monitor the implementation and effectiveness of this policy, through the structured general manager’s forums, which will contribute to the development of an appropriate environmental and sustainability management culture across G&H.

This Privacy Policy applies to your use of our Site and to how we may use your information in doing business with you or your organization. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) as it has effect in the UK (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified or that can be uniquely associated with you. Personal data includes information such as your name and contact details, but it also covers other information such as identification numbers, electronic location and biometric data, financial and account information and other online identifiers.

Under the GDPR, and other applicable laws, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.
2. The right to access the personal data we hold about you. Part 12 will tell you how to do this.
3. The right to have your personal data corrected if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 14 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.

Further information about your rights can also be obtained from the Information Commissioner’s Office or, in the United Kingdom, your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

Depending upon your use of our Site, or the nature of your commercial relationship with us, we may collect some or all of the following personal and non-personal data (please also see Part 13 on our use of Cookies and similar technologies):

• Name
• Address
• Email address
• Telephone number
• Business name
• Job title
• Profession
• Information about your preferences and interests
• IP address
• Web browser type and version
• Operating system
• A list of URLs starting with a referring site, your activity on our Site, and the site you exit to
• Pages visited
• Documents or literature downloaded

Under the GDPR and other applicable laws, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your Account
• Providing and managing your access to our Site
• Personalising and tailoring your experience on our Site
• Supplying our products or services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products or services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by sending an email to this effect to marketing@gandh.com).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. You will have the option to opt out of any email we send you from our mailing list and you can contact us to have your details removed, or to check what we have on file for you, at any time. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable law and you will have the opportunity to opt-out of our processing of your information in many circumstances.

We generally will keep your data for so long as we require it for the uses described in this Policy, up to a period of ten years.

If you submit a query through one of our contact forms however, we will store your enquiry in our website database for up to 12 months.

If you sign up to our newsletter we will store your information with our mailing list service provider until you unsubscribe, or until you ask us to delete your information.

We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

We may transfer your data to a third party based in the United States. Where this is the case we have taken appropriate measures to require that your Personal Information will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information in accordance with European Union and UK data protection law. Further details can be provided upon request.

Where we share your data with external third parties, which are based outside of the EEA or the UK, the following safeguards are applied to such transfers:

The data centers where customer data is processed and hosted follow industry best security practices. For data in transit, secure data transmission with strong encryption is used..

We host our website and some data with Netlify.

We use Campaign Monitor to help us manage our contacts database. You can read more about how they handle your data on their website here.

We use Google Analytics to help us measure and understand traffic to our website, but we employ IP anonymization so that visitors’ IP addresses are masked before they are processed or stored. Please contact us using the details below in Part 14 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

Other than third party processing outlined in Part 8 above and in this Part 9, we will not share any of your personal data with any third parties for any purposes, subject to the exception listed below. We do not sell your personal data.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other companies in our group to facilitate our commercial relationship with you, or companies working with us to help us fulfil our services to you. Our technical support agency NetConstruct may need to see your data in order to help us with any technical enquiries.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

We may transfer your personal data to a business that acquires all or a portion of our business or into which we merge our business.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as it has effect in the UK, as explained above in Part 8.

10.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/or at the point of providing your details).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

You may access our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to sign in and submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 13.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

You can make this request online. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

We may transfer your personal data to a business that acquires all or a portion of our business or into which we merge our business.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please complete a contact form, available on the contact us page.

If you are an individual residing in California, you may have additional rights with regard to the information we gather about you. Upon verifiable written request and to the extent required by California law, we will provide to you information regarding the personal information we gather about you, the types of sources from which we obtain the information, the purposes for which the information is gathered, and the types of third parties with which we share or to whom (if any) we sell the information. In addition, upon verifiable request or when required or otherwise appropriate and to the extent required by California law, we will grant you reasonable access to or copies or other compilations of the personally identifiable information that we hold about you provided that you establish to our reasonable satisfaction that you are the person whose personal information is requested. We may deny such access where the denial is permitted by applicable law and every request from an individual will be assessed on a case by case basis. In the event a request is denied, we will notify you regarding the reasons for the denial in writing. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage) to the extent permitted under applicable law. In addition, we will take reasonable steps to permit you to correct or amend personally identifiable information that is demonstrated to be inaccurate or incomplete. We also will delete personal information we have gathered about you when you make a verifiable request that we do so, except to the extent applicable law permits or requires us to maintain that information. To guard against fraudulent requests for access, we will require sufficient information to allow us to confirm the identity of the individual making the request before granting access or deleting the information. To exercise your rights under this Part 14, please contact us as described in Part 12.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy, as far as regards use of the website, on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date if you have any concerns.