Data Protection Policy

Thunderbird Fried Chicken is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out Thunderbird Fried Chicken’s commitment to data protection and individual rights and obligations in relation to personal data and in accordance with GDPR.

The policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees. As well as to the personal data of customers and other personal data processed for business purposes.

Thunderbird Fried Chicken has an appointed data protection officer. This role is to inform and advise the organisation on its data protection obligations. They can be contacted at GDPR@thunderbirdckn.co.uk.

Questions about the policy, or request for further information should be directed to GDPR@thunderbirdckn.co.uk.

“Personal Data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation or biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

Thunderbird Fried Chicken processes personal data in accordance with the following data protection principles:

• Personal data is processed lawfully, fairly and in a transparent manner
• Personal data is collected only for specific, explicit and legitimate purposes
• Personal data is processed only where it is adequate, relevant and limited to what is necessary for the purpose of processing
• Inaccurate personal data is rectified or deleted without delay
• Thunderbird Fried Chicken keeps personal data only for the period necessary for processing
• Thunderbird Fried Chicken adopts appropriate measures to make sure that personal data is secure and protected against unauthorised or unlawful processing and accidental loss, destruction or damage
• Thunderbird Fried Chicken tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its Privacy Notices. It will not process personal data of individuals for other reasons
• Where Thunderbird Fried Chicken relies on its legitimate interests as the basis for processing data; it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of the individuals

Where Thunderbird Fried Chicken process special categories of personal data or criminal data to perform obligations or exercise rights in employment law, this is done in accordance with the policy on special categories of data and criminal records data.

The organisation will update personal data promptly if an individual advises that his/ her information has changed or is inaccurate.

Personal data gathered during employment is held in the individual’s personal file (in hard copy, electronic format or both) and on HR/ Payroll systems. The periods for which the organisation holds personal data are contained in its Privacy Notice to individuals.

Thunderbird Fried Chicken keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulations (GDPR)

As a data subject, individuals have a number of rights in relation to their personal data.

Subject Access Requests

Individuals have the right to make a subject access request.

If an individual makes the subject access request, Thunderbird Fried Chicken will tell them:

1. Whether or not their data is processed and if so why, the categories of personal data converted and the source of the data if it is not collected from the individual
2. To whom their data is or may be disclosed
3. For how long their data is stored
4. Their right to complain to the Information Commissioner if they think that Thunderbird Fried Chicken has failed to comply with their GDPR rights
   Whether or not Thunderbird Fried Chicken carries out automated decision making and the logic involved in any such decision making
5. Thunderbird Fried Chicken will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically unless they agreed otherwise

To make a subject access request, the individual should send their request to GDPR@thunderbirdckn.co.uk. In some cases, they may be asked to provide proof of identification before a request can be processed. Thunderbird Fried Chicken will inform the individual if it needs them to verify their identity and the documents it requires.

Thunderbird Fried Chicken will normally respond to a request with a period of one month from the date it is received. In some cases, such as where Thunderbird Fried Chicken will need to process large amounts of the individual’s data, it may respond within three months of the original request. Thunderbird Fried Chicken will write to the individual within one month of the original request to tell them that this is the case.

If a subject access request is manifestly unfounded or excessive, Thunderbird Fried Chicken is not obliged to comply with it. Alternatively, Thunderbird Fried Chicken can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Thunderbird Fried Chicken has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify them that this is the cane and whether or not it will respond to it.

Other Rights

Individuals have a number of other rights. They can require Thunderbird Fried Chicken to rectify inaccurate data:

• Stop processing or erase data that is no longer necessary for the purpose of processing
• Stop processing or erase data if the individual’s interest overrides the organisations legitimate grounds for processing data
• Stop processing or erase data if processing is unlawful
• Stop processing data for a period if the data is inaccurate or if there is a dispute about whether or not the individual’s interests override
• Thunderbird Fried Chicken’s legitimate grounds for processing data
• To ask Thunderbird Fried Chicken to take any of these steps, the individual should send the request to GDPR@thunderbirdckn.co.uk

Thunderbird Fried Chicken takes the security of personal data seriously. Thunderbird Fried Chicken has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure and to ensure that data is not accessed except by employees in the proper performance of their duties.

Where Thunderbird Fried Chicken engaged with third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to an individual’s rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purpose for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

If Thunderbird Fried Chicken discovers that there has been a breach on personal data that poses a risk to the rights of individuals, it will report it to the Information Commissioner’s Office (ICO) within 72 hours of discovery. Thunderbird Fried Chicken will record all data breaches regardless of their effect.

If the breach is likely to result is a high risk to the rights of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

Thunderbird Fried Chicken will not transfer personal data outside of the EEA except where it is required as part of the individual’s employment with Thunderbird Fried Chicken.