We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. This privacy notice/policy explains how we collect and use your personal data, during and after your relationship with us, in accordance with our obligations under data protection legislation. It also covers who we share it with and what rights you have with regards to your personal data and how you can exercise those rights.
For the purposes of the General Data Protection Regulation (“GDPR”) Bunzl UK Limited trading as Keenpac is the Data Controller. The scope also includes personal data that is collected through our websites, by telephone, through Live Chat and through any related social media applications. This means that we determine what data is collected, how this data is going to be used and how this data is protected. 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 data about you, so that you are aware of how and why we are using such information. If you have questions about how we process personal data, or would like to exercise your data subject rights, please use the information supplied in the Contact Us section below.
We may collect, store, and use the following categories of personal data about you (please note this list is not exhaustive):
We collect personal data from you for one or more of the following purposes:
In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
In section 10 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.
We believe that it is in our legitimate interests, or is necessary for the performance of a contract, or we obtain consent to collect and use personal data to operate our business and to provide a service that you have requested. In some cases, we may be under a legal duty to use or disclose personal data, for example to comply with a request from an official body. When we process on the lawful basis of legitimate interest, we ensure our interests and fundamental rights do not override your interests.
We may share your personal data, but this will be done on a ‘need to know’ basis and only where it is necessary to do so or where we are required to share information. Such as our professional advisors and service providers including:
We may also share personal data:
We aim to put the necessary safeguards in place to ensure that personal data that the company is legally responsible for remains properly protected and is used appropriately when in the hands of a third party. We may share personal data when we buy or sell any business or assets. We aim to put the necessary safeguards in place to ensure that personal data that we are legally responsible for remains properly protected and is used appropriately when shared with third parties.
We are a global organisation and use third parties located in other countries to help us run our business, including other companies within the Bunzl Group in some circumstances. This includes countries outside the “EU” and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU. We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data.
We will take steps to keep your data for only as long as is necessary for our business needs and in compliance with any legal or regulatory duties to retain personal data for a particular period. However long we retain personal data for, we will ensure it is subject to appropriate security. To 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.
We will implement measures to protect your data, including appropriate security measures 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 individuals, agents, contractors and other third parties who have a business need to know. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
As a data subject whose personal data we hold, you have certain rights. If you wish to exercise any of these rights, please use the information supplied in the Contact Us section below. To process your request, we will ask you to provide a valid form of identification for verification purposes. Your rights are as follows:
As a Data Controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice/policy and any related communications we may send you.
You have the right to request a copy of the personal data we hold about you (or having it transferred to another organisation) free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you, how we are using it, who we are sharing it with and how we obtained your data.
You have the right to ask us to rectify or correct any of your personal data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete. This may be used with the right to restrict processing to make sure that incorrect/incomplete data is not processed until it is corrected/complete.
You have the right to request that we erase/delete your personal data in certain circumstances, for example where no overriding legal basis or legitimate reason continues to exist for processing personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
You have the right to ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure.
You have the right to request your set of personal data be transferred to another Data Controller or Processor, provided in a commonly used and machine-readable format. This right only applies to data you have given us, the original processing was on the basis of consent/explicit consent/fulfilment of a contractual obligation and the processing is by automated means (is held electronically).
You have the right to object to our processing of your personal data where
a) Processing is based on legitimate interest (including profiling);
b) Processing is for the purpose of direct marketing; or
c) Processing is for the purpose of a task carried out in the public interest.
In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If the personal data is being used to make automated decisions about you as the data subject (e.g. profiling), to be told what logic the system uses to make those decisions and to be able to request human intervention to override any such automated decisions
You are not required to pay any charge for exercising any of your rights. We have one month to respond to you.
You are never required to provide personal data to us, but you may need to do so when you enter into a contract for the provision of our services or products. We will not be able to provide our services or products unless you provide us with the personal data, we need to do so.
In addition, you will be required to provide certain personal data if you contact us to exercise your rights under GDPR as set out in section 10.
We may carry out automated decision-making when you use our website. The automated decision making involves providing content to you based on your online behaviour obtained using Cookies. If consent is given for Cookies which are more than those required for essential use of the website, we will be able to display content that is relevant to you. Please refer to paragraph 14 below.You can adjust cookies through the cookie preference settings.
Yes, we may use your personal data to carry out marketing within the Bunzl group of companies. We will only contact people who want to receive marketing as well as for our own legitimate interests. If you object to marketing, whether electronic or otherwise, please let us know and we will stop contacting you for marketing. We may still need to contact you for the purposes of providing services and products.
We use cookies, which are small text files placed on your computer by websites that you visit, to make our website work properly, to monitor its usage and to display content that we believe will be relevant to you. If you register with us or if you continue to use our site, we may ask if we can collect additional data from you automatically through cookies or similar technology. You will be asked to agree to our use of them through our cookie consent tool. You can also block cookies by adjusting your browser settings. However, if you choose to block all cookies you may not be able to access all, or parts, of our site and some features will not work properly.
Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to privacy-brhs@bunzl.co.uk.
Alternatively, you can contact us at the following postal address:
GDPR Privacy Champion
c/o Gordon Reynolds
Keenpac
29 Centurion Way
Meridian Business Park
Leicester
LE19 1WH
We have appointed a Data Protection Privacy Champion to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact us. If you have any concerns about our use of your personal data, we would like the opportunity to respond to your concerns. You can make a complaint to us using the contact details above. You have the right to contact the Information Commissioner’s Office (ICO) if you are unhappy with our response to your concerns. The ICO is the independent regulatory office dealing with the Data Protection Act 2018 and the General Data Protection Regulation across the UK.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://ico.org.uk/global/contact-us/
Bunzl UK is incorporated in the UK, outside the EU, so we have appointed Bunzl Ireland Limited as our representative for the purposes of the GDPR compliance, and to deal with any supervisory authorities or data subjects in this respect at the following address:
Bunzl Ireland Limited (Co ref 662881)
Arthur Cox Building
Earlsfort Terrace
Dublin 2
Ireland
We reserve the right to update this privacy notice at any time; this policy was last updated February 2023.
BUNZL UK LIMITED
Company number 02902454
ICO reg. Z6579777
BUNZL IRELAND LIMITED
Company number IE114401
