BAPSH Ltd PRIVACY NOTICE

INTRODUCTION
The British Association for the Purebred Spanish Horse Ltd (BAPSH Ltd) is a data controller registered with the UK Information Commissioner’s Office (Registration Number: ZA373396).

Our address is:- The British Association for the Purebred Spanish Horse Ltd, Holly Trees Farm, Chesterblade Road, Stoney Stratton, Shepton Mallet, Somerset, BA4 4EQ, United Kingdom.
Our Data Protection Officer can be contacted by Email: info@bapsh.co.uk or by telephoning our office on 01749 838791.

The British Association for the Purebred Spanish Horse Ltd (BAPSH Ltd), is committed to protecting and respecting your privacy at all times. In this document references to “we”, “us”, “our”, means the BAPSH Ltd. We aim to be clear and transparent regarding how we process your personal data, but should you have any queries, we would be happy to discuss them with you.

This Privacy Notice (together with any other documents referred to in it) sets out the basis on which any personal data you provide to us, or we obtain, will be processed by us

WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU
In order to provide you with our services and comply with the law and regulations by which we are bound, we will need to collect and process personal data about you. If you do not provide the information we require, whether it’s necessary to enter into a contract with you and/or comply with our legal and regulatory obligations, it may delay or prevent us from meeting our obligations and may unfortunately mean that we will not be able to provide our services or products to you.

Types of Personal Information
Contact                    –    Your title, full name, address where you live, email address, and telephone number/s

Socio-demographic –  Nationality

National Identifier  –  The number or code of your national identity document; required for ANCCE-LGPRE services

Date of Birth         –     Required for ANCCE-LGPRE Breeder Code and Owner Code applications

Locational             –     Studfarm address or addresses

Contractual           –     Details about the services and products we provide to you

Communications –    What we learn about you from letters, emails and our conversations with you, when
the information is relevant to your horse ownership/s past, present, and future.
Consents               –     Any permissions, consents, or preferences you give to us, including how you want us to contact you.

HOW WE COLLECT PERSONAL INFORMATION
We collect your personal information in a variety ways which are given below:

Information you give to us
i)   when you apply to register a foal or an imported horse via our application forms,
ii)  when you apply to change the ownership of a horse, or to update your ownership contact details via our application forms
iii) when you apply for services from the ANCCE-LGPRE via our application forms and those of the ANCCE-LGPRE
iv) when you communicate with us by post, telephone, SMS, email, social media, or via our website
v)   as you interact with us in other ways; as a service provider, a contractor, a provider of goods, or in any other capacity

Information we receive from third parties
i) information provided to us by the ANCCE-LGPRE  (ANCCE-LGPRE Data Protection/Privacy Notice –  https://www.lgancce.com/web2/page/proteccion-datos   , & ANCCE-LGPRE Legal Notice – https://www.lgancce.com/web2/page/aviso-legal  )
ii) information provided to us by DEFRA, Equine Register Ltd (Central Equine Database), other Equine Passport Issuing Organisations and Registration bodies, the Food Standards Agency, Trading Standards, local government, law enforcement agencies, horse rescue agencies, and other similar – Link to DEFRA Fair Processing Notice Feb2018
iii) information provided to us by third parties such as horse sellers/dealers/agents, horse-importers/exporters, horse transporters, equine insurers, and equine veterinarians.
WHY WE COLLECT YOUR PERSONAL DATA; THE LAWFUL REASON WE RELY ON TO PROCESS IT, & WHAT WE USE YOUR DATA FOR.
Data Protection law says that we are only allowed to process your personal information if we have one or more of the following lawful reasons:

1) To comply with our legal duty and obligations under Equine legislation EU 2015/262 and EU 2016/1012
2) To fulfill a contract with you
3) When it is in our legitimate interest
4) When you give us your consent

What does the term ‘Legitimate interest’ mean ? Extensive information on this subject can be found on the ICO website via this link – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/
In specific situations, we may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our National Studbook and PIO business and which does not materially impact your rights, freedom or interests.

WHO INFORMATION MAY BE SHARED WITH
We sometimes need to share the personal information we process with the individual them-self and also with other organisations. Where this is necessary we are required to comply with all aspects of the Data Protection Act (DPA). What follows is a description of the types of organisations with whom we may need to share some of the personal information we process for one or more reasons.

Where necessary or required we share information with:

• Family, associates and representatives of the person whose personal data we are processing
• Equine Register Ltd – Data Processor on behalf of DEFRA for the UK Central Equine Database (CED)
• DEFRA – Data Controller  – Link to DEFRA Fair Processing Notice Feb2018
• Other UK Equine Passport Issuing Organisations
• Equiventus Ltd – Data Processor on behalf of The British Association for the Purebred Spanish Horse Ltd
• ANCCE-LGPRE – Worldwide Mother Studbook for Purebred Spanish Horses based in Sevilla, Spain. Data Controller   – ANCCE-LGPRE Data Protection/Privacy Notice –  https://www.lgancce.com/web2/page/proteccion-datos   , & ANCCE-LGPRE Legal Notice – https://www.lgancce.com/web2/page/aviso-legal
• Local Authorities, the Police Service, Trading Standards
• Food Standards Agency
• Equine Rescue Organisations in the UK
• Suppliers and service providers
• Equine Insurance Companies
• Equine Veterinary Practices

TRANSFERRING PERSONAL DATA OUTSIDE OF THE EEA
Occasionally we may need to collect or send some personal information outside of the EEA, for horse registrations, changes of ownership/updates, and for horse passports. If we transfer personal information to countries or jurisdictions which do not have a similar standard of data protection law in place, we will only do so to fulfill our contract with you and we will inform you in advance of the need to transfer the information.

YOUR RIGHTS
Under the Law you have various rights in relation to your information.
1. A copy of your information
You may request access to your personal data at any time by contacting us in writing, accompanied by documentary proof of your identity.  BAPSH will provide you with a copy of your information as soon as possible and within one month of receiving your request.
Access is free of charge if your request is not excessive or unfounded. Otherwise we are entitled to charge an administrative fee or we may refuse to respond; in either case an explanation will be sent to you. If a large amount of information is involved we may ask you to specify the information you wish to access.
We are obliged to verify your identity by whatever means we deem appropriate before complying with your request.
2. If you think your information is incorrect
You can ask us to correct your information if you think some part of it is incorrect.  Please contact us in writing with details of the correction, and we will amend your information as soon as possible and within one month of receiving the request from you.
When your information has been shared with a third party, we will try to contact them to tell them the changes you request.
If the information correction is a change of address that under Equine Law should have been updated within 30 days of the change of address on our application form for this purpose, we will send you the Change of Address form to be completed and returned to BAPSH Ltd with the appropriate fee and the relevant Equine Passports for updating.
3. What to do if you want us to stop using your information
You have the right to object to us using your information, ask us to restrict our use of it or ask us to delete it if there is no need for us to keep it. However Equine Law prevents us from deleting your personal data in relation to any horse you have registered with BAPSH Ltd currently or historically. We may also be unable to delete your information where we need it to fulfill our contract with you or comply with the Law or to deal with a legal claim.
You can ask us to stop processing your information where we are doing so for our legitimate interests as defined previously, or where you wish to withdraw your consent.  This can be done by writing by post or by email to our Data Protection Officer at BAPSH Ltd Registry Office, Holly Trees Farm, Chesterblade Road, Stoney Stratton, Shepton Mallet, Somerset, BA4 4EQ, or Email address:-  info@bapsh.co.uk

HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will hold your personal information for as long as is necessary according to the lawful reason your data was acquired. In some circumstances the law will require us to retain your personal information indefinitely When your personal information is no longer required it will be deleted or anonymised.
Data retention periods:-
a. Passport records are kept indefinitely, in order to comply with our legal obligation,
b. Complaints records are kept indefinitely, in order to administer and manage ongoing complaints and, where appropriate, provide a baseline for tracking complaints against centres/individuals for future reference to make informed decisions
c. Records of Basic Grading events and BAPSH Shows are kept indefinitely as part of the Studbook historical records.
d. Records of other events are kept for 2 years, in order to facilitate any insurance claim resulting from the activity
e. Staff records are kept indefinitely, in order to comply with pension and tax obligations
f. Expenses records are kept for 7 years, in order to comply with our legal obligation
g. Marketing records are kept for 2 years, in order to carry out marketing within the legitimate interest of our business
h. Merchandise purchase records are kept for two months, in order to administer the fulfillment of the order

CHANGES TO THIS PRIVACY NOTICE
Our Privacy Notice is under regular review and may change from time to time. Any amendments will be added to the online Privacy Notice on our website www.bapsh.co.uk.
Privacy Notice updated 22- May-2018.

MAKING A COMPLAINT ABOUT HOW WE TREAT YOUR PERSONAL INFORMATION
Please contact our Data Protection Office by email or in writing if you are unhappy with any aspect of how we treat your personal information.
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioners Office (ICO) by contacting them at:- www.ico.org.uk, or by telephone on 0303 123 1113 (+44 1625 545 700), or by post to:-
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

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BAPSH Ltd Cookie Policy

The British Association for the Purebred Spanish Horse Ltd (BAPSH Ltd) is a data controller registered with the UK Information Commissioner’s Office (Registration Number: ZA373396).

BAPSH Ltd is committed to protecting and respecting your privacy and will comply with the applicable data protection laws in all our dealings with your personal data.

We use cookies and similar technologies (herein referred to in general as “cookies”) for a variety of purposes on our website.  Cookies are small files that are stored on your browser when you visit a website.  The main purpose is to keep a record of your visit, time spent on the site, pages visited and searches made. We may also use cookies to automatically collect information from your computer when you visit our sites, and automatically store it in the log files.  This may include information on type of browser software, website activity and IP address.

The main purposes of the cookies we use are:

• Session – to allow the user to navigate our sites more easily; for example you don’t have to go in as a new user every time.
• Analytics – to improve the user experience of the site by providing statistics on how the site is used.
• Tracking – we may use cookies hosted by third parties which allow for an improved site experience by collecting data such as browser, IP address, pages visited, content viewed, timing of visits and clickstream data. When you visit our websites or open an email we have sent, we may place a cookie on your browser.
• Authentication – this enables us to identify you and therefore where appropriate, personalise information for you.

How to Refuse and Delete Cookies

You can refuse to accept all or some cookies by modifying settings within your browser – for help on how to do this visit https://www.aboutcookies.org.uk  You may also delete all cookies on your browser – click help on your browser or visit https://www.aboutcookies.org.uk

Please remember that if you block the session cookies you may be unable to access certain parts of our sites.

May 2018