THE PURPOSE OF THIS DOCUMENT
London Hotel Group (LHG) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us in accordance with the General Data Protection Regulation (GDPR). It applies to all those who use our services and facilities.
LHG is a “data controller” which means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice which applies to current and former employees, workers and contractors. This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We shall comply with data protection law which requires that the personal information we hold about you must be: (a) used lawfully, fairly and in a transparent way (b) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes (c) relevant to the purposes we have told you about and limited only to those purposes (d) accurate and kept up to date (e) kept only as long as necessary for the purposes we have told you about (f) kept securely.
THE INFORMATION WE HOLD ABOUT YOU
Individual personal data (personal information) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We shall collect, store, and use the following categories of personal information about you:
[1] full name and address including country of the person making the reservation
[2] date of birth, nationality and passport details
[3] bank/credit/debit card details through which payment for services will be paid
[4] previous reservations/engagement with the business
[5] CCTV/video footage of the customer/client for identification purposes.
This data is held on the hard drive of the relevant PC/server (see Safeguarding Data below) and the gathering of such personal data is necessary for the business to provide accommodation and other services to those customers/clients who contract for them.
COLLECTION OF YOUR PERSONAL INFORMATION
We collect personal information about those staying with us or using our services and/or facilities through the booking system. When a booking is made through Online Travel Agents (OTA) or wholesalers or third parties (such as Booking.com) the individual personal data of the customer are held by the respective agency and this information is accessed through secure passwords by London Hotel Group via the extranet or from the PMS (property management system software) that has a direct integration with the online channels. The only persons having access to such data are authorised staff with system log-in credentials (reception/ reservations/ managers). When a booking is made in person at Reception either by telephone or being physically present personal data is gathered by the receptionist and will also be accessed by the accounts department in order to ensure that proper payment is made. Those persons referred for accommodation by the local authority will have been identified by the local authority to LHG through their name and contact number: on arrival at LHG their name, contact number and signature will be retained together with the referral letter from the local authority as a manual record.
USE OF INFORMATION ABOUT YOU
We shall use your personal information only as the law allows. Most commonly, we shall use your personal information in the following circumstances: (a) where we need to perform the contract we have entered into with you (b) where we need to comply with a legal obligation (c) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare: (a) where we need to protect your interests (or someone else’s interests) (b) where it is needed in the public interest [or for official purposes].
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests; this may include conducting data analytics studies to review and better understand guest movements and preferences.
We shall use your personal information only for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we shall notify you and explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent in compliance with the above provisions where this is required or permitted by law.
DATA SECURITY
We have put in place measures to protect the security of your information as set out in our Data Protection & Management Policy available on our website. These include appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; limitation of access to your personal information to those employees, agents, contractors and other third parties who have a business need to know, who are subject to a duty of confidentiality; procedures to deal with any suspected data security breach of which we shall notify you and any applicable regulator of a suspected breach where we are legally required to do so. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
COOKIES
Like many other commercial websites, our website may employ a standard technology called a ‘cookie’ to collect information about how our website is used. A cookie is a small data file that a web site can send to and leave on a visitor’s PC hard drive to keep records of visits to the site. On their own, cookies do not contain or reveal any personal information. This information may be linked to the data stored in the cookies by turning them off in your web browser. However, without accepting a cookie, you cannot access the pages on this website.
DATA RETENTION
We shall retain your personal information only for as long as necessary to fulfil the purposes for which we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention and destruction of data are set out in our Data Protection & Management Policy.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law, you have the right to: (a) request access to your personal information (commonly known as a “data subject access request”) which enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully (b) request correction of the personal information that we hold about you so as to enable you to have any incomplete or inaccurate information we hold about you corrected (c) request erasure of your personal information which enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below) (d) object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground; you have the right also to object where we are processing your personal information for direct marketing purposes (e) request the restriction of processing of your personal information which enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it (f) request the transfer of your personal information to another party; if you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact The General Manager, London Hotel Group, Lynton House, 54 Clapham Common South Side, London SW4 9BX in writing.
You will not have to pay a fee to access your personal information or to exercise any of the other rights. We may charge a reasonable fee, however, if your request for access is clearly unfounded or excessive or we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Human Resources at the address above. Once we have received notification that you have withdrawn your consent we shall no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time and will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice, please contact The General Manager, London Hotel Group, Lynton House, 54 Clapham Common South Side, London SW4 9BX in writing.