Black Country Cryogenics is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations.
We hold personal data about our customers, suppliers and other individuals for business purposes.
This policy sets out how we seek to protect personal data and ensure that we understand the rules governing the use of personal data.
Business purposes
The purposes for which personal data may be used by us:


Personnel, administrative, financial, regulatory, payroll and business development purposes.


Business purposes include the following:

-     Compliance with our legal, regulatory and corporate governance obligations and good practice


-     Operational reasons, such as recording transactions




Personal data
‘Personal data’ means 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.

Personal data we gather may include: individuals' phone number, email address.
Special categories of personal data
Special categories of data include information about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
Data controller
‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
Data processor
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation
The principles
Black Country Cryogenics shall comply with the principles of data protection (the Principles) enumerated in the EU General Data Protection Regulation. We will make every effort possible in everything we do to comply with these principles. The Principles are:

1. Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

2. Limited for its purpose

Data can only be collected for a specific purpose.

3. Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4. Accurate

The data we hold must be accurate and kept up to date.

5. Retention

We cannot store data longer than necessary.

6. Integrity and confidentiality

The data we hold must be kept safe and secure.

Accountability and transparency

We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle.

To comply with data protection laws and the accountability and transparency Principle of GDPR, we must demonstrate compliance. we are responsible for understanding particular responsibilities to ensure we meet the following data protection obligations:


·        Fully implement all appropriate technical and organisational measures

·        Maintain up to date and relevant documentation on all processing activities

·        Implement measures to ensure privacy by design and default, including:

o   Data minimisation

o   Transparency

o   Creating and improving security and enhanced privacy procedures on an ongoing basis


Our procedures

Fair and lawful processing


We must process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.


If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased


Controlling vs. processing data



As a data processor, we must comply with our contractual obligations and act only on the documented instructions of the data controller. If we at any point determine the purpose and means of processing out with the instructions of the controller, we shall be considered a data controller and therefore breach our contract with the controller and have the same liability as the controller. As a data processor, we must:


·        Not use a sub-processor

·        Co-operate fully with the ICO or other supervisory authority

·        Ensure the security of the processing





Lawful basis for processing data

At least one of the following conditions must apply whenever we process personal data:


1.   Consent


We hold recent, clear, explicit, and defined consent for the individual’s data to be processed for a specific purpose.


2.   Contract


The processing is necessary to fulfil or prepare a contract for the individual.


3.   Legal obligation


We have a legal obligation to process the data (excluding a contract).


4.   Vital interests


Processing the data is necessary to protect a person’s life or in a medical situation.


5.   Public function


Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.


6.   Legitimate interest


The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.






Our responsibilities


·        Analysing and documenting the type of personal data we hold

·        Identify the lawful basis for processing data

·        Ensuring consent procedures are lawful

·        Store data in safe and secure ways

·        Checking and scanning security hardware and software    regularly to ensure it is functioning properly

·        Researching third-party services, such as cloud services the company is considering using to store or process data



Accuracy and relevance


We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.


Individuals may ask that we correct inaccurate personal data relating to them.






Storing data securely



·        Data stored on a computer should be protected by strong passwords that are changed regularly.

·        All possible technical measures must be put in place to keep data secure



Rights of individuals
Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:

1. Right to be informed

·        Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language.


2. Right of access

·        Enabling individuals to access their personal data and supplementary information

·        Allowing individuals to be aware of and verify the lawfulness of the processing activities

3. Right to rectification

·        We must rectify or amend the personal data of the individual if requested because it is inaccurate or incomplete.


4. Right to erasure

·        We must delete or remove an individual’s data if       requested and there is no compelling reason for its continued processing.


5. Right to restrict processing

·        We must comply with any request to restrict, block, or otherwise suppress the processing of personal data.



6. Right to data portability

·        We must provide individuals with their data so that they can reuse it for their own purposes or across different services.

·        We must provide it in a commonly used, machine-readable format, and send it directly to another controller if requested.

7. Right to object

·        We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.

·        We must respect the right of an individual to object to direct marketing, including profiling.

·        We must respect the right of an individual to object to processing their data for scientific and historical research and statistics.