K PAK LIMITED POLICY REGARDING THE GENERAL DATA PROTECTION REGULATIONS (GDPR) 

AND THE RETENTION OF PERSONAL INFORMATION. 

25 MAY 2018  

 

The privacy of our clients is important to us. This document tells you how we at K Pak Limited use the information you give us and how we protect your privacy.   It also explains your rights under the General Data Protection Regulations.  To function in the Freight Forwarding Industry and handle the complexities of clearance through the relevant Customs procedures in the UK and Worldwide, K Pak require and store for future reference, certain forms of personal information and data.  This document covers the handling of such personal information as defined in the General Data Protection Regulation (GDPR). 

 

The Requirements of the GDPR. 

The GDPR comes into effect from 25th May 2018.  It replaces the 1998 Data Protection Act and builds upon it’s requirements and principles.  From a retention point of view, the key Principle is E, the ‘Storage Limitation’ Principle, which states as follows: 

Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. 

  

Collecting Information and Protecting Your Privacy.  

Our aim is to ensure your artwork, antiques and possessions of value to you, are handled with the utmost care and efficiency.  In providing this service we may need to obtain from you, and store for future use, certain personal information about you, for example your current address and contact details, bank details, VAT and EORI numbers etc.  This information may be passed to other companies, within the UK and outside, who we will work with in moving your consignment to its point of destination.   This information may be required by the customs authorities within the UK and in the country of origin or ultimate destination of your consignment.  

 If you are unable or unwilling to provide some or all of this information, K Pak Limited may be unable to provide you with a comprehensive service to meet your needs and circumstances.   We do not collect personal information from third parties. 

 

K Pak Limited is committed to protecting your privacy and, as we hope you return as a client in the future, we would like you to have confidence that we will keep your personal information confidential and secure, and only keep it for as long as is necessary.   The criteria we use to determine how long this period is can be obtained from K-Pak Ltd at the address below.  We will use it with care and it will only be shared in the ways explained in this document, or if we are required to by Law. 

 

Your personal information will only be held for as long as necessary and collected for the purposes of providing you with a service and advice in respect of handling, packing, transporting and storing your artwork and possessions in the manner you have requested.  In addition, we will make every effort to ensure that the information you provide is recorded accurately and that it is only passed to companies who comply with the General Data Protection Regulations.   If it is required to send your information abroad, we will endeavour to do so within the European Union (EU) or to a third country that the EU has determined provides an adequate level of protection and where you are able to exercise your rights to access your personal information under the General Data Protection Regulations.   However, if your consignment has a country of origin or destination outside these areas, your consent to provide personal data for the completion of the service you have engaged K Pak Limited for, is on the proviso that such information must be provided outside the protection of the General Data Protection Regulations.  Customs Clearance, handling and delivery arrangements abroad will all require the provision of elements of personal data, and in providing this information you understand that it will be passed abroad should the need be, in order to complete the service we have been engaged for.  

 

Storage Locations. 

K Pak Ltd stores this personal data in a number of locations:

• Within the Company I.T. system.

• In archived paper files within Unit 21, Liongate Enterprise Park in locked cabinets. 

 

Storage Security. 

K Pak Limited will endeavour to ensure the comprehensive protection and secure archiving of all records and documentation during the relevant storage periods, via the following means:

• Premises locked and alarmed when not occupied.

• Entry to business premises and working offices via key pad entry system and comprehensively covered by CCTV.

• Physical storage areas separate from working offices and accessed via electronic fob entry system.  Comprehensively covered by CCTV.

• Computer systems accessed via password-entry, changed quarterly.

• Computer systems protected via a firewall and user authentication. 

K Pak Limited are an Authorised Economic Operator, authorised at level AEOF.    

We are also CAA Regulated Agents, Authorisation Number UK/RA/00887-01/0817, with all staff members meeting the relevant training standards required of this authorisation. 

Furthermore, K Pak Ltd.’s security systems are audited and inspected by GRASP (Global Risk Evaluations Limited), to ensure they reach the highest levels of protection within the industry.    

 

Definition of acceptable storage periods & K Pak Limited’s Policy. 

HMRC advise that we are ‘required to keep records for all traded goods you declare to HMRC for four years, for duty and tax purposes and for government statistics’.  The exception to this is if there is a criminal investigation taking place when a ten-year retention period must be adhered to.  

K-Pak have taken the decision to store Customs documentation for a maximum period of seven years, to allow for the additional work carried out post clearance date for most consignments.   

When the seven-year point is reached, all physical documentation will be shredded and destroyed. 

 

Controlling and using your personal information.  

A ‘Data Controller’ is someone who determines the purpose for which and the way your personal data should be processed.   K Pak Limited and the companies we may use during the process of shipping, customs clearing and handling your possessions are all Data Controllers.     

We use your information in a variety of ways:

• To enable us to handle worldwide shipments through International Customs boarders and territories.

• To help with administration.

• To contact you with details of changes to regulations and processes.

• For business analysis and research.

• To comply with the Law.

• To verify your identity, if necessary, by searching publicly available records.

• To prevent fraud and money laundering, we may pass your details to other companies, public bodies including the police or to an insurer’s database.   

 

We therefore process your data because it is necessary for:

• The performance of a contract to which you are a party.

• Compliance with legal obligations to which we, as the controller, are subject. 

 

Marketing and Sharing Your Information  

K Pak Limited will never sell your details to a third party, but we may share your information with a company we are associated with, in the process of completing the service you have engaged us to carry out.  Therefore we (or they) may contact you (by mail, email, telephone or other appropriate means) to discuss services with you.   You can ask us not to contact you for this reason at any time, by writing to our office address.  

We may send your information to third parties that are carrying out work on your and our behalf.  

 

Your Rights under the General Data Protection Regulations.

You have certain right under the regulation which include the right to:

• Ask us to restrict processing of your personal data.

• Request any information we hold which may be incorrect, amended.

• Stop us contacting you with any marketing information.

• Ask us for a copy of your personal information. 

 

As the processing of your personal information may be necessary for the legal obligations placed upon us by Her Majesty’s Revenue & Customs (HMRC), we will not be able to permanently delete your personal information until the end of the period we have deemed necessary.  

 

Tax Accounting Requirements. 

Companies are required to keep tax records (VAT, Corporation tax etc) for at least 6 years after the end of the financial period to which they relate.  

 

For more information  

If you would like further details about how we use your personal information, or if you have any data protection concerns or questions, please write to: 

 

The Data Protection Officer K Pak Limited Unit 21, Liongate Enterprise Park Morden Road Mitcham Surrey CR4 4PH 

 

Our Privacy Policy may change from time to time and all updates will be posted on this page.