GDPR

At Waddington Europe, we strive to honour the privacy and security of our users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by Waddington Europe and any of its affiliates acting as a Controller under relevant data protection rules and regulations.

Personal Data

When you submit a request or electronically pass information to any Waddington Europe entity (including, but not limited to, contact details), you are sometimes asked to provide certain information, including, but not limited to, your name, title, company, address, phone number, e-mail address and line of business. You may also be providing us with data regarding your device, your client or supplier account, etc. These kinds of data will in many circumstances be considered as personal data under applicable data protection legislation.

Please consult the table below to see for which purposes we process (use, store, etc.) personal data, as well as the legal grounds for such processing and the relevant retention period.

Purpose

Customer management (provision of services; invoicing; customer support; …)

Categories of personal data

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics of data subjects and, in some cases family members (age, gender, civil status, …)

Legal grounds

  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in managing our customer relationships*
  • Legal obligation to process data

Direct consumer sales customer management (provision of services; invoicing; customer support; …)

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in managing our customer relationships*
  • Legal obligation to process data
  • Your consent

Know your customer (anti-fraud; anti-money-laundering; …)

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in managing our customer relationships*
  • Legal obligation to process data

Direct marketing**

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Legitimate interests of Waddington Europe in promoting and improving our products and services*
  • Your consent

Supplier management (accounting; …)

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in managing our supplier relationships*
  • Legal obligation to process data

Maintaining the security of our people and assets

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in protecting our business and employees*
  • Legal obligation to process data

Litigation management

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Performance/conclusion of a contract with you
  • Legitimate interests of Waddington Europe in protecting our business and defending our legal interests*
  • Legal obligation to process data

Product/service improvement & business intelligence

  • Identification data (name, address, telephone, ...)
  • Electronic identification data (e-mail, IP-addresses, cookies, ...)
  • Financial characteristics (bank account number, credit card details, …)
  • Personal characteristics (age, gender, civil status, …)
  • Legitimate interests of Waddington Europe in promoting and improving our products and services*
  • Your consent

* Based on a balancing test. For more information, see above for our contact details. 
** If you wish to object to the use of your personal data for these purposes, see section 9.3 below.

In addition, we may, pursuant to valid legal processes, such as a search warrant, subpoena, or court order, allow access to any information (including such categories of personal data) provided to Waddington Europe, in order to comply with such process and to protect our rights and property. If warranted, we may also allow access to this information in special emergencies where physical safety is at risk.

Waddington Europe moreover reserves the right to disclose any information obtained from or about you to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of Waddington Europe’s assets.

Except as otherwise set forth herein, we do not sell, trade, or rent your personal data with any third parties outside of Waddington Europe.


Data Transfers

These categories of personal data may be transferred to other Waddington Europe entities for such purposes, as well as to any third parties to whom the relevant Waddington Europe entity subcontracts all or part of this processing. This may for instance include e-marketing service providers, hosting providers and any other relevant roles.

In the event of a transfer of personal data to a country outside of the European Economic Area, Waddington Europe systematically ensures the application of an adequate level of protection of such personal data by approved means (e.g. selecting “Privacy Shield”-certified processors or putting in place standard contractual clauses on the processing of personal data, in accordance with the EU Commission model clauses). You can request more information about such measures (including copies where relevant) by getting in touch with Waddington Europe through the contact details above.


Your Rights

Subject to applicable law, you may have some or all of the following rights in respect of your personal data. You can exercise these rights by submitting your request (i) to your local customer service team; or (ii) to our Data Privacy Committee at we.hr@novolex.com. You will need to include your personal details as well as some means of verifying your identity (e.g. copy of identity card or driving license). Please note that Waddington Europe may reject requests that are excessive or a misuse of the relevant right.

Access right

You may have the right to obtain confirmation of whether Waddington Europe processes personal data in relation to you and, if so, gain access to a copy thereof. For certain kinds of data, you may also have a right to data portability.

Data accuracy: the right of rectification and right to erasure

You may have the possibility to rectify or obtain the erasure of your personal data, provided that the applicable legal requirements are met. The right to erasure is subject to various exceptions, notably as regards personal data whose processing is necessary to support litigation or for compliance with statutory retention requirements.

Limits to processing: the right to restriction, right to object & consent withdrawal

In addition, you may have the right to object to the processing of personal data based on Waddington Europe’s legitimate interests (see table above) and to otherwise obtain the restriction of certain forms of processing in specific circumstances. In particular, in relation to the processing of personal data for direct marketing purposes, you may have the right to object at any time thereto. Where any processing is based on consent, you may have the right to withdraw such consent at any time (without this affecting the processing prior to the consent withdrawal).

Right to lodge a complaint with supervisory authorities

You may have the right to lodge a complaint with the supervisory authority, in particular the data protection authority that is competent for your place of residence or the lead supervisory authority for Waddington Europe, namely The Information Commissioner’s Office of Wycliff House, Water Lane, Wilmslow, Cheshire SK9 6AF, United Kingdom, www.ico.co.uk.


Children

Waddington Europe does not knowingly collect information from children. If Waddington Europe learns that a child has provided it with personal data, it will use reasonable efforts to remove such information from its files.


User's Acknowledgement

By visiting the Web Site, you acknowledge that you have (had the opportunity to) become familiar with Waddington Europe’s privacy policy.

We reserve the right, at our sole discretion, to change, modify, add, or remove portions from this privacy policy at any time. We shall notify any such changes in according with applicable data protection legislation.


Corporate Records Policy

At Waddington Europe, we strive to honour the privacy and security of our employees, users, customers and suppliers, as well as their representatives, in relation to all products, services, applications and websites provided by Waddington Europe and any of its affiliates acting as a Controller under relevant data protection rules and regulations. As Waddington Europe values the trust and privacy of all parties, it strives to process this information (“personal data”) in a responsible and legally compliant manner.

We will generally only retain data:

  • for the period required to serve the applicable purpose;
  • to the extent reasonably necessary to comply with an applicable legal requirement; or
  • as advisable in light of an applicable statute of limitations or of applicable legal requirements.

Data Retention Schedule

Data Type

Period held
(after leaving or disassociation)

Who has access?
(after leaving of disassociation prior to deletion)

Payroll & Employee records

8 years

HR

Personal file storage & Emails

8 years

IT

Customers & Vendors

Depersonalised at 6 months – buying history held indefinitely

Customer Services and Procurement

Temporary agency employees

6 months

HR

Job Applicants – UK and NL

6 months

HR

Job Applicants - Ireland

2 Years

HR

CCTV Footage

21 days maximum

Data Protection Officer

This Notice attempts to provide you with all the information you need regarding the retention of data, but if not, please get in touch with our Data Privacy Officer at we.hr@novolex.com. The Data Privacy Officer will do its best to answer any questions you may have.


Waddington Europe - Data Controllers

Holfeld Plastics Limited

Avoca River Park,
Arklow,
County Wicklow Y14 NX44
Ireland

Par-Pak Europe Limited

37-39 Burners Lane,
Milton Keynes,
Buckinghamshire MK11 3HA
United Kingdom

Eureka CaterWare B.V.

Schaapherderhof 9,
2988 CP Ridderkerk,
Netherlands - Registered No. 24453510
Rotterdam, Netherlands

A&J Plastics Limited

Brue Avenue,
Colley Lane,
Bridgewater,
Somerset TA6 5YE
United Kingdom

DeltaForm Limited

Brue Avenue,
Colley Lane,
Bridgewater,
Somerset TA6 5YE
United Kingdom

Waddington Europe Limited

37-39 Burners Lane,
Milton Keynes,
Buckinghamshire MK11 3HA
United Kingdom


Subject Access Request Policy

As a Company, we recognise and ensure compliancy to data legislation. Under the EU’s General Data Protection Regulations (GDPR), individuals now have the right to request access to their personal data from businesses.

Policy Outline

This policy details the process of subject access requests (SARs) and how an individual can obtain the data stored about them within Waddington Europe.

Internal SAR Process

As an employee of Waddington Europe, you have the following rights in respect of your personal data. You can exercise these rights by completing the application for access to your personal data form at the end of this document and returning by post or email to our Data Privacy Committee at we.hr@novolex.com. You will need to include your personal details as well as some means of verifying your identity (e.g. copy of identity card or driving licence). Please note that Waddington Europe may reject requests that are excessive or a misuse of the relevant right.:

  • Access to own employee data: you have the right to request an overview of your personal data being processed by (or on behalf of) Waddington Europe. Where this is reasonably possible we will give you information regarding the source, type, purpose and categories of recipients relevant to your personal data. You also have the right to obtain a copy of the personal data held about you. This right of access can normally be exercised free of charge, but we reserve the right to charge an appropriate administrative fee where permitted by applicable law, for instance where you request multiple copies of your personal data.
  • Accuracy and right of rectification: you have the possibility to have your personal data rectified or erased, provided that the applicable legal requirements are met. In the event of errors, we will, upon notification, correct personal data we hold regarding you. You may request erasure in the event where personal data is no longer required to attain the purposes sought, or 4 where its processing is unlawful. The right to erasure is nevertheless subject to various exceptions, notably as regards personal data which processing is necessary to support litigation or for compliance with statutory retention requirements.
  • Right to object to or withdraw consent: in certain circumstances (e.g. where your personal data is processed on the basis of Waddington Europe’s legitimate interests), you have the right to object to the processing of your personal data on the basis of compelling grounds related to your particular situation and in accordance with applicable law. In specific circumstances, you also have the right to obtain the restriction of certain forms of processing. If the processing of your personal data is based on your consent, you have the right to withdraw your consent to such processing at any time. It is worth noting that the withdrawing of consent has no impact on earlier processing on such basis.
  • Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority. With respect to the processing of your employee personal data, this is the competent supervisory authority of the country in which you work, details of which can be provided on request by the Data Privacy Committee at we.hr@novolex.com.

We will respond to your request within one month with either the data requested or to notify that more time is required to fulfil the request, this will be a maximum of two additional months.

External SAR Process

Subject to applicable law, you may have some or all of the following rights in respect of your personal data. You can exercise these rights by completing the application for access to your personal data form at the end of this document and returning by post or email (i) to your local customer service team; or (ii) to our Data Privacy Committee at we.hr@novolex.com. You may need to include your personal details as well as some means of verifying your identity (e.g. copy of identity card or driving licence). Please note that Waddington Europe may reject requests that are excessive or a misuse of the relevant right.

  • Access right: You may have the right to obtain confirmation of whether Waddington Europe processes personal data in relation to you and if so, gain access to a copy thereof. For certain kinds of data, you may also have a right to data portability.
  • Data accuracy: right of rectification and right to erasure. You may have the possibility to rectify or obtain the erasure of your personal data, provided that the applicable legal requirements are met. The right to erasure is subject to various exceptions, notably as regards personal data whose processing is necessary to support litigation or for compliance with statutory retention requirements.
  • Limits to processing: right to restriction, right to object & consent withdrawal. In addition, you may have the right to object to the processing of personal data based on Waddington Europe’s legitimate interests (see table above) and to otherwise obtain the restriction of certain forms of processing in specific circumstances. In particular, in relation to the processing of personal data for direct marketing purposes, you may have the right to object at any time thereto. Where any processing is based on consent, you may have the right to withdraw such consent at any time (without this affecting the processing prior to the consent withdrawal).
  • Right to lodge a complaint with the supervisory authorities. You may have the right to lodge a complaint with the supervisory authority, in particular the data protection authority that is competent for your place of residence or the lead supervisory authority for Waddington Europe, namely The Information Commissioner’s Office of Wycliff House, Water Lane, Wilmslow, Cheshire SK9 6AF, United Kingdom, www.ico.co.uk.

We will respond to your request within one month with either the data requested or to notify that more time is required to fulfil the request, this will be a maximum of two additional months.

Download the Personal Data Access Form