Client Privacy Notice

Introduction:

• Protecting the personal information of our clients is extremely important to JollyDays. It’s especially important to a company like ours, as we are entrusted to look after a large amount of sensitive personal information. The way we collect and share client information is equally important.

• This Privacy Notice sets out how we collect and process client personal data in accordance with the Data Protection Act (2018). Further updates to the Act may be introduced however, the most recent version will always be available on our website, www.jollydaysholidays.co.uk.

• Our Clients include support teams, professional care workers, family members, and friends, and often a combination of these.

• The JollyDays policy on the protection of personal information also extends to JollyDays Staff members and External Suppliers.

• The lawful bases for client data processing within JollyDays is:

‘Consent’ - Personal data may be processed on the basis that the data subject has consented to such processing.

‘Contractual necessity’ - Personal data may be processed on the basis that such processing is necessary in order to fulfil our contractual obligations as a holiday provider; and

‘Legitimate Interests’ - The processing of your data is necessary for your legitimate interests, (in arranging your holidays), or the legitimate interests of a third party (such as a hotel or airline), unless there is a good reason to protect your personal data which overrides those legitimate interests.

What is Personal Information?

• This includes information about an individual that can identify them, such as their name, address, e-mail address, telephone number and medical details. It can relate to clients, family members, care and support workers, other stakeholders, employees, business contacts and suppliers.

The Information You Give Us:

• This is information about you that you and/or your support network freely provides us with when you wish to make use of our services. This may be by telephone, via our website, mail and e-mail, completion of questionnaires.

What Client information do we hold?

• Contact Details:
o Your name;
o The name(s) of your support worker(s) or care team;
o The name(s) of your next-of-kin family member(s);
o The name and practice of your Doctor;
o All applicable telephone numbers, with address and e-mail address, as relevant.

• Personal Details, including the following:
o Your date of birth;
o Your photograph;
o A copy of your passport;
o A copy of your current Travel Insurance document, as applicable;
o Your National Health Number;
o Special categories of personal information, such as gender, medical profile.

How we use this Personal data:

• To carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services that you request from us;

• To provide you with information we feel may be of interest to you;

• To notify you about changes to our service;

• To administer our internal operations.

Who we might share Personal data with:

• Any member of our company. This will include the partners, all administrative staff, couriers and support workers;

• Selected 3rd parties including suppliers or sub-contractors, for the performance of any contract we enter into with them, in the fulfilment of the service we provide for you. This will include airlines, ferry companies, Eurotunnel, hotel and other accommodation venues we select for your holidays;

• Any prospective buyer of the JollyDays organisation, in the event that a potential sale of its business assets arises in the future.

Using Client Data for Marketing Purposes:

• We may use your data for legitimate marketing purposes, where we believe our services will be of interest to you. We shall only send you marketing literature where you have consented to such contact, or in the case of products and services, where these will be similar to those we have previously provided to you. We may use the following media to communicate this information to you:
o Telephone calls, post, e-mail, website, holiday brochure, social media
You have the right to request that we do not send you this literature via any media combination, at any time.

How long will we hold Client data for?:

• We hold your data only for as long as is necessary for any particular purpose for which we hold it, unless there are any legal or operational reasons to hold it for a longer period;

• When determining a retention period, we shall take into account the following points:
o Our legal obligations under applicable law, to retain data for a certain period of time;
o The Statute of Limitations under applicable law;
o (Potential) disputes.
o Guidelines issued by relevant supervisory authorities

Where we store your personal data:

• The entire database of your information is stored at our JollyDays premises. We take all steps necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

• Some of the data we collect from you may be transferred to, and stored at, a destination outside of the United Kingdom (“UK”). It may also be processed by staff operating outside of the UK, who either work for us or our suppliers. This includes staff engaged in the fulfilment of your contract with us.

• Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, and have contractual processes in place with our business suppliers to do this, we cannot guarantee the security of your data transmitted to our site. Once we have received your information, we shall use all relevant procedures and security features to try and prevent unauthorised access.

Clients’ rights in respect of the personal data we hold:

• You are within your legal right to see a copy of the information we hold about you, and to request corrections and updates be made where necessary. We would expect to provide this information within one month of receipt of your request, free of charge. However, we may make a charge in exceptional situations where the request is excessive. We do not have to provide information in all cases, such as where it would involve the disclosure of information about another person, or where a request is excessive or manifestly unfounded;

• You have the right to be informed about the information we hold on you, in a structured, commonly used and machine readable format;

• You can ask us to erase, amend or restrict any data that we hold about you for any of the following reasons:
o You wish to terminate your contract with us, in which case the data is no longer necessary for the purposes for which it was collected or otherwise processed;
o You therefore withdraw your consent to the processing, and there is no other legal ground for the processing; o You object to processing for direct marketing purposes;
o The personal data has to be erased in order to be compliant with a legal obligation in Union or Member State law to which we are subject;
o You object to processing because of your own particular situation, pending the verification of whether our legitimate grounds for processing override your concern.

• Where you have previously given us your permission to use your personal information and later wish to withdraw that permission, you are required to inform us via email or post. Once we have received this notification we will no longer process your personal data for the purposes you originally agreed to unless we have another legitimate interest or legal requirement to do so.

Advice and Assistance:

• Questions, comments and requests regarding this Privacy Notice are welcomed, and should be addressed to JollyDays Supported Holidays Worldwide LLP, Unit 3B, Hill Farm, Church Lane, Ford End, Chelmsford , Essex, CM3 1LH.

Changes to this Privacy Notice:

• We keep our Privacy Notice under regular review. It was last updated on 22nd June 2018. Future updates will be available on request or via our website, www.jollydaysholidays.co.uk