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OUR PRIVACY POLICY

INTRODUCTION

The Mole Valley Farmers group of companies respect your privacy and are committed to protecting your personal data. This privacy policy aims to give you information on how the group collects and looks after your personal data when you visit any of our websites, including www.molevalleyfarmers.com (regardless of where you visit them from), when you purchase products and services from the group (through our websites or in store), when you open a customer account, become a member, register with the group or when you otherwise contact the group. It will also tell you about your privacy rights and how the law protects you.

References to "you" or "your" are to you as an individual using our websites or otherwise contacting the group (either on behalf of yourself, your business or another individual or organisation).

 
 

1. IMPORTANT INFORMATION

1.1 It is important that you read this privacy policy together with OUR COOKIE POLICY and any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

1.2 This version was last updated on 24th October 2022.

1.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Our website is not intended for children and we do not knowingly collect data relating to children.

1.5 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.

 

2. who we are

2.1 Mole Valley Farmers Limited is a company registered in England and Wales with company registration number 00679848 and registered office at Exmoor House Lime Way, Pathfields Business Park, South Molton, Devon, EX36 3LH, United Kingdom. The group of companies operating under the Mole Valley Farmers brand (and to whom this policy applies) is made up of different legal entities including, Mole Valley Feed Solutions Ltd, Mole Energy Limited and Mole Valley Farmers also trades under various brand names including Mole Country Stores and Mole Valley Plus. This privacy policy is issued on behalf of the Mole Valley Farmers group of companies so when we mention "Mole Valley Farmers", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Mole Valley Farmers group of companies responsible for processing your data.

2.2 We operate the ecommerce website, www.moleonline.com, as well as other related websites and various retail stores. We provide products and services to business and consumer customers, and we operate memberships and customer accounts. As such, we need certain personal information to be able to deliver our products and services and operate our memberships and customer accounts.

2.3 We are bound by applicable data protection laws in respect of the handling and collection of your personal data. We are registered as a data controller with the Information Commissioner's Office (ICO) under the following registration numbers:

  • Mole Valley Farmers Limited: Z5493646

  • Mole Valley Feed Solutions Ltd: ZA032291

  • Molecare Veterinary Services Ltd: ZA357798

  • Mole Energy Limited: 07215578

2.4 If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in section 12, please contact us using the contact details in section 13.

 

3. THE DATA WE COLLECT ABOUT YOU

3.1 Personal data, or 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) or data relating to a corporate entity.

3.2 We may collect, use, store and transfer different kinds of personal data about you, your staff or your business, which we have grouped together as follows:

  • Identity Data includes first name, last name, title, date of birth, Mole Valley Farmer Membership and/or customer account numbers, country parish holding (CPH) number and Red Tractor membership number.

  • Contact Data includes business or home address, billing and delivery address(es), email address(es), landline and mobile number(s) and fax number(s).

  • Financial Data includes bank account number, sort code, payment card details and credit references and checks.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

  • Profile Data includes your username and password, purchases and orders made by you, your browsing history, account preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and, where applicable, third parties and your communication preferences.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or Transaction Data for financial reporting and analysis. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.4 We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, we may process certain special categories of personal data and/or information about criminal offences when you:

  • have an accident in or near our store that is then logged in our accident record book;

  • are involved in carrying out criminal activity that is captured on one of our CCTV systems; and

  • include such information in your CV which you (or a third party) send to us about employment opportunities with us.

 

4. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services or open up a customer account or membership). In this case, we may have to suspend or cancel a product or service you have with us but we will notify you if this is the case at the time.

 

5. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

5.1Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

  • purchase any of our products and services from our websites or in store;

  • set up a customer account with us (as an individual, sole trader, partnership or on behalf of a corporate entity;

  • become a member or shareholder of Mole Valley Farmers;

  • meet with one of our members of staff to discuss our products and services or otherwise contact us. If you contact Mole Valley Plus by telephone, this conversation may be recorded but you will be informed about this at the beginning of the call;

  • request marketing and publications to be sent to you;

  • enter a competition, promotion or survey; or

  • give us some feedback.

5.2Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please seeOUR COOKIE POLICY.

5.3Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Cardstream Limited based inside the EU and Verifone Limited based outside the EU;

  • Financial Data from credit reference agencies such as Experian;

  • Technical Data from analytics providers such as Google based outside the EU;

  • Identity and Contact Data from data brokers or aggregators such as Marketlocation based inside the EU; and

  • Identity and Contact Data from publicly available sources such as websites of relevant, prospective customers, Companies House, Red Tractor (Assured Food Standards) and Government agencies such as DEFRA.

 

6. HOW WE USE YOUR PERSONAL DATA

6.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.

  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

  • Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing material to you via email, post, phone, text message and social media. You have the right to withdraw consent to marketing at any time by contacting us (see section 6.2 below).

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To process and deliver product orders and provide our services to you, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Sending you statements and invoices

(d) Operating the Mole Valley Farmers websites including our booking systems

(e) Calculate points to award loyalty bonus

(a) Identity

(b) Contact

(c) Profile

(d) Financial

(e) Transaction

(f) Marketing and Communications

(a) Performance of a contract with you, where you are an individual or sole trader

(b) Necessary for our legitimate interests (to provide our services to our customers (i.e. when you are an individual who works for and on behalf of our customers and to recover debts due to us)

To register a new membership including providing you with relevant details about benefits of membership including our monthly and quarterly newsletters

(a) Identity

(b) Contact

(c) Profile

(d) Financial

(f) Marketing and Communications

(a) Performance of a contract with you, where you are an individual or sole trader

(b) Necessary for our legitimate interests (to provide our products and services (and related information) to our members (i.e. when you are an individual who works for and on behalf of our member))

To register a new customer account including:

(a) Running credit and other reference checks to ensure that we can give credit

(b) Provide relevant details about benefits of the customer account

(a) Identity

(b) Contact

(c) Profile

(d) Financial

(f) Marketing and Communications

(a) Performance of a contract with you, where you are an individual or sole trader

(b) Necessary for our legitimate interests (to provide our products and services (and related information) to our customers (i.e. when you are an individual who works for and on behalf of our customer))

To manage our relationship with you or our customer which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you, where you are an individual or sole trader

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)

To enable you to complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you, where you are an individual or sole trader

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods, services, offers, events (shows and meetings) and newsletters that may be of interest to you (including by email and phone)

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

(a) Necessary for our legitimate interests (to develop our services and grow our business)

(b) Where you have provided your consent

To respond to requests for information regarding suspected or actual criminal activity including fraud

(a) Identity

(b) Contact

(c) Transaction

(d) Technical

(e) Profile

(f) Usage

(a) Necessary for our legitimate interests (to prevent and detect crime and fraud)

(b) Necessary to comply with a legal or regulatory obligation

(c) Necessary to protect the vital interests of you or another individual

To assist in emergency situations and deal with accidents in-store

(a) Identity

(b) Contact

(a) Necessary to protect the vital interests of you or another individual

6.2Prospecting

In a business-to-business context, we may make contact with you to provide or seek information in connection with our products and/or services. The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interest in doing business together. When we make contact with you, you can exercise your right to object to such contact (please see section 12.1.4).

6.3Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

  • Unsubscribe link displayed on every email newsletter and marketing communication (which links to your online preferences); and

  • Text "STOP" to opt-out.

6.3.1 Marketing from Us

Our newsletters:

We will send members our monthly and quarterly newsletters as we believe this is one of the benefits of being a member. The legal basis on which we process personal data for these purposes is our legitimate interest to develop our products and services and grow our business, and your interest in receiving discounts on products.

You can ask us to stop sending you the newsletter at any time (see section 6.3.3 below).

Marketing calls and post:

Where you are a member or an account holder, we may contact you by phone or via post to tell you about new products, services and offers from us and our carefully selected third parties. The legal basis on which we process personal data for these purposes is our legitimate interest to make our products and services available to those that may need them and to grow our business, and your interest in receiving information about new products, services and offers.

You can ask us to stop calling or contacting you in this way at any time (see section 6.3.3 below).

Other marketing communications:

We will only send other marketing communications to you as a member, customer account holder and/or other customers if you have provided your express, opt-in consent. We may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us after you have requested information from us or opened a customer account or become a member and, in each case, you have opted-in to receiving that marketing.

You can withdraw your consent at any time.

6.3.2 Marketing from third parties

We will get your express consent before we share your personal data with any company outside Mole Valley Farmers for marketing purposes, including our group companies (including Mole Valley Feed Solutions Ltd) and our joint venture companies including Mole Energy Limited, Mole Insurance Services (a trading style of Arthur J Gallagher Insurance Brokers Ltd) and Molecare Veterinary Services Limited.

6.3.3 Opting Out / Unsubscribing

You can ask us or our third parties to stop sending you marketing messages at any time by logging onto the Mole Valley Farmers website under marketing preferences (if you are a customer account holder or member) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out / unsubscribe links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the services to you).

6.4 Change of Purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

7. DISCLOSURES OF YOUR PERSONAL DATA

For the purposes set out in section 6, we may have to share your personal data with the following parties:

7.1Internal Third Parties such as other companies in the Mole Valley Farmers group of companies where they provide services on our behalf.

7.2External Third Parties such as:

  • Service providers and suppliers acting as processors based in the UK who provide delivery, haulage, storage, IT, operating system and system administration services.

  • Original equipment manufacturers, suppliers and retailers acting as processors or joint controllers based in the UK who provide the products and services to us (or sometimes straight to you) and they may answer your product specific queries or contact you about a delivery. We may also contact these providers to seek a quote on your behalf, but would not pass your personal data on to them until one provider has been selected.

  • In relation to Mole Valley Plus, we may pass your details on to third party suppliers where you have asked us to introduce you to a specific supplier (acting as a joint controller). The contract for any such product or service resulting from our introduction would be between you and the third party supplier (not us).

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators, law enforcement bodies, police and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected or actual fraud or tax evasion).

  • Marketing and PR providers where you have agreed to a publication or article with us.

  • Third party references where we have requested a reference from you in order to open a customer account and/or membership for you.

  • Other third party companies (who act as a controller) where we have an agreement in place and only where you have agreed that we may share your Identity and Contact Data with them, such as our other group companies, our joint venture companies and carefully selected third parties for marketing if you have given your consent to receive such marketing.

7.3Specific Third Parties such as:

  • Experian plcbased within Europe who provide us with credit check data and references when you request to open a customer account and/or become a member.

7.4Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7.5We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

8. CCTV

8.1 We may operate CCTV and other surveillance systems in (and around) our stores which capture images of you. We may be able to identify you from the CCTV data. We will only use this data to prevent, detect, deter and report on crime, to protect our buildings and assets from crime, to protect the health and safety of customers, staff and other visitors and/or to assist with criminal investigations and support law enforcement bodies.

8.2 We use CCTV systems in this way for our legitimate interests (to prevent and detect crime), to comply with legal or regulatory obligations (to law enforcement bodies) and/or to protect the vital interests of you or another individual.

8.3 Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are requested by a law enforcement body, data will be kept by them for as long as they need it. In all other cases, recorded images will be kept for no longer than 60 days. We will maintain a comprehensive log of when data is deleted.

8.4 We will not disclose CCTV images to members of the public requesting access or copies of CCTV images. We will pass images to relevant third parties i.e. Police or Insurance providers upon official requests.

 

9. INTERNATIONAL TRANSFERS

Certain of our external third parties are based outside the European Union (EU) so their processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

 

10. DATA SECURITY

We have put in place appropriate security measures (including SSL technology) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

WWe have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

11. DATA RETENTION

How long will you use my personal data for?

11.1We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11.3We will generally retain our customers' data for a period of 7 (seven) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or defend our legal rights, or for tax purposes.

11.4Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every twelve (12) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a "do not contact" list).

11.5Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services), subject to section 11.3, we will retain your data for twelve (12) months.

11.6In some circumstances you can ask us to delete your data: see section 12.1.3 below for further information.

11.7In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

12. YOUR LEGAL RIGHTS

12.1Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

12.1.1Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

12.1.2Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

12.1.3Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

12.1.4Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

12.1.5Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

12.1.6Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

12.1.7Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us directly.

12.2No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

12.3What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

12.4Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

13. Contact Details and Complaints

Our full details are:

Full name of legal entity:

Data Protection Officer:

Email address:

Postal address:

Telephone number:

Mole Valley Farmers Limited

Vicky Price

[email protected]

Mole Valley Farmers Limited
Dartmoor House
Pathfields Business Park
South Molton
EX36 3LH
United Kingdom

01769 576433 or 07772 898618

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.