Privacy Policy

Welcome to Highfield Group privacy notice.

If you are an individual:

This privacy notice applies to information held about you. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.

Wherever we say “you” or “your” this means you as our customer.

If you are a business:

This privacy notice applies to information held about you and the individuals connected to your business by us as data controllers, as described below.  It explains what information we collect about you and individuals who are connected to your business, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.

Wherever we say “you” or “your” this means you and any individuals connected to your business.  An individual connected to your business could be any director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, your attorney or representative, agent or nominee, or any other persons or entities whom you have a relationship with that’s relevant to your relationship with us.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how  Highfield Group collects and processes your personal data, including any data you may provide when you engage our services.

It is important that you read this privacy notice together with any other privacy notice 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 notice supplements the other notices and is not intended to override them.

Controller

Highfield Group is the controller and responsible for your personal data (collectively referred to as “Highfield Group”, “we”, “us” or “our” in this privacy notice).

Contact details

Our full details are:

Full name of legal entity: Highfield Plant Services Limited

Email address: sales@Highfield-group.co.uk

Postal address: Brow Cottage, Preston Rd, Charnock Richard, Chorley PR7 5JR

Telephone number: 01257 754071

You have the right to make a complaint at any time to the Information Commissioner’s Office (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.

Changes to the privacy notice and your duty to inform us of changes

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.

2. The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• CCTV data includes images collected of you either at our premises or in the vicinity of our vehicles.
• Data that you’ve provided to us

We do not knowingly collect the following Special Categories of Personal Data about you:  details about your 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.

It is possible that we collect details about your race and ethnicity when processing CCTV images.  In this instance processing is necessary for reasons of substantial public interest in order to:

 

• prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
• for the personal safety of staff, visitors and other members of the public and to act as a deterrent against crime;
• to support law enforcement bodies in the prevention, detection and prosecution of crime; and
• to assist in the defence of any civil litigation.

3. How is your personal data collected?

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

• Direct interactions. You may give us your Identity, Contact and Financial Data and other information about you and individuals connected to your business by filling in forms or by corresponding with us by post, phone, email or otherwise.
• CCTV operations. We may record and store information about you from CCTV at any of our premises or attached to our vehicles.
• Automated 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.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from brokers or intermediaries.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.

4. How we use your personal data

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.

Purposes for which we will use your personal data

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..

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or supplier	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order and carry out your instructions including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Collect and deliver consignments	(a) Identity (b) Contact (c) Financial (d) Transaction (e) CCTV	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you 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 (c) Investigating and resolving complaints (d) Recovering money which you owe	(a) Identity (b) Contact (c) Profile (d) CCTV	(a) Performance of a contract with you (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/services)
To administer and protect our business including: (a) data analysis, testing, system maintenance, support, reporting and hosting of data) (b) undertaking risk management (c) protecting our legal rights and complying with our legal obligations	(a) Identity (b) Contact (c) Technical (d) CCTV	(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

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.

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.

5. Disclosures of your personal data

We may have to share your personal data for the purposes set out in the table above with external third parties such as:

• Subcontractors who we might engage to carry out some or all of the services we provide to you.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third 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 notice.

We 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.

International transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 the Europe and the US.

6. Data security

We have put in place 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 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.

We 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.

7. Data retention

How long will you use my personal data for?

We 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.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Some data we are required to maintain for a minimum period of time, examples include:

• CCTV video recordings at our premises and onboard our vehicles on a rolling monthly recording, or longer where it is necessary for the establishment, exercise or defence of legal claims;
• Invoices to customers (comprising names, addresses, telephone numbers, email addresses, payment details), delivery notes to customers and invoices to suppliers for a minimum of 10 years or longer where it is necessary for the establishment, exercise or defence of legal claims.
• Quotations and estimates for a minimum of 2 years following the expiry of the quotation or longer where it is necessary for the establishment, exercise or defence of legal claims.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:

• Request 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.
• Request 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.
• Request 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.
• Object 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.
• Request 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.
• Request 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.
• Withdraw 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.

Should you wish to enforce any of your rights listed above, please email sales@highfield-group.co.uk and let us know.

 

MODERN SLAVERY POLICY

This Policy applies to Highfield Plant Services Limited and all subsidiaries. This policy sets out the commitments of our company in relation to modern slavery. We recognize that we have a responsibility to take a robust approach to slavery and human trafficking and our organization is committed to preventing it in our business activities and ensuring that our supply chains are free from, slavery and human trafficking. As part of the Construction industry, we recognize that we have a responsibility to take a robust approach to slavery and human trafficking. Our organization is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. This policy applies to employees at all levels, directors, officers, volunteers, agents, contractors, external consultants and business partners. This policy does not form part of any employee’s contract of employment, and we may review and amend this policy at any time. It will be reviewed on a regular basis to ensure it complies with relevant UK legislation. Changes to this policy will be notified by publishing the updated version on our intranet site. PURPOSE Modern slavery is a crime and a violation of fundamental human rights. It takes various forms as shown below, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We will raise awareness of modern slavery and our expectations of what should be done to address any issues or suspicions, through this policy and associated training.

There are a number of crimes that are covered under the definition of modern slavery; these are: • Bonded labour – individuals who are forced into debt by paying to get a job or mandatory equipment or have their passports taken to restrict their movements. • Forced labour – individuals who are forced to work long hours for little or no pay in poor conditions, under verbal or physical threats to themselves or their families. • Trafficking – individuals or groups moved from one area to another for forced or bonded practices. • Criminal exploitation – where a victim is exploited to commit a crime, for example, pickpocketing, shoplifting, drug trafficking, and cannabis cultivation. • Sexual exploitation – including sexual abuse, forced prostitution, and abuse of children for the production of images or videos. • Domestic servitude – where an individual is forced to work in private households with restricted freedom and work long hours for little or no pay. Less commonly identified crimes include organ removal, forced marriage, and illegal adoption. AIM We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships, and to ensuring modern slavery is not taking place anywhere in our own business or our supply chain. In our supply chain, we ask our suppliers to implement due diligence for their own suppliers and subcontractors to ensure there is no slavery or human trafficking in their supply chain. As an equal opportunities employer, we are committed to creating and ensuring a non- discriminatory and respectful working environment for our staff. We want all employees to feel confident that they can expose wrongdoing without any risk to themselves. Our recruitment and people management processes are designed to ensure that all prospective and current employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion. We take a strict approach to acts, actions, and behaviors deemed to be in breach of this policy statement, and any such incidents will be dealt with in accordance with the applicable Disciplinary Procedure. Breaches of this policy statement may amount to gross misconduct resulting in summary dismissal.

We may terminate its relationships with other individuals and organizations if they are believed to have breached this policy. Policies: HR is responsible for putting in place and reviewing policies and the process by which they were developed. • Risk assessments: HR, Procurement, and Operations are responsible for ensuring risk assessments are conducted and reviewed and discussed with the board any concerns for final sign-off. • Investigations/due diligence: HR is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking, and recommendations and actions are presented to the Board for approval. • Training: HR ensures that everyone within and connected with our business operations understands and responds to the identified slavery and human trafficking risks and completes the companies e-learning before commencing any work with us. Relevant policies We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations: Whistleblowing policy – We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns. Employee code of conduct – Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. • Supplier/Procurement code of conduct – We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions.

However, serious violations of our supplier code of conduct will lead to the termination of the business relationship. • Recruitment/Agency workers policy – We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Due diligence We undertake due diligence when considering taking on new suppliers, and regularly review its existing suppliers. Our due diligence and reviews include: • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking. • evaluating the modern slavery and human trafficking risks of each new supplier. • Review on a regular basis all aspects of the supply chain based on the supply chain mapping. • conducting supplier audits or assessments through our own staff and third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified; • creating an annual risk profile for each supplier. • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through third-party auditor and requiring them to implement action plans. • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular “Stronger together” or “Ethical trading” initiatives. • using the ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship. Performance indicators We have reviewed our key performance indicators (KPIs). As a result, we: • require all staff to have completed training on modern slavery by December of each year. • Developed a system for supply chain verification which has been in place since July 2022 whereby we evaluate potential suppliers before they enter the supply chain;

• Reviewed our existing supply chains by July 2022, whereby we evaluate all existing suppliers. • We review and verify all our supply chains annually each year. Training We require all staff within the company to complete training on modern slavery as a module within our wider human rights/ethics/ethical trade e-learning programme. This is required to be completed within the first week of joining the business and to re-sit annually. Our modern slavery training covers: Our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline; • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available. • how to identify the signs of slavery and human trafficking. • what initial steps should be taken if slavery or human trafficking is suspected? • how to escalate potential slavery or human trafficking issues to HR. • what external help is available, for example through the Modern Slavery Helpline, Gangmasters, and Labour Abuse Authority and “Stronger together” initiative? • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and • what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains. Awareness-raising programme As well as training staff, we have raised awareness of modern slavery issues by distributing flyers to staff, displaying posters across our premises, e-learning platform. The above explains to staff: • the basic principles of the Modern Slavery Act 2015. • how employers can identify and prevent slavery and human trafficking.

• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and • what external help is available, for example through the Modern Slavery Helpline. RESPONSIBILITIES Caddick Construction Limited and all subsidiaries • Actively works to ensure that the risk of modern slavery within its own business activities, and that of its supply chain, is minimised and will adhere to the requirements of all relevant local and national laws. • Ensures our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors, and business partners at the outset of a business relationship and is reinforced as appropriate thereafter. • Provides employees and managers with appropriate information and training in order to ensure effective communication and understanding of, and compliance with, this policy. • Prohibits employees at all levels, directors, officers, and representatives of the business from making threats of violence, harassment, or intimidation, committing acts of discrimination, and confiscating workers original identification documents. • Prohibits child labour and the use of worker-paid recruitment fees. • Ensures workers have freedom of movement, freedom of association and the right to resign from their employment with the company. • Encourages the reporting of any incidents or suspicions by all employees and is committed to taking appropriate action without undue delay. Employees • Must familiarise themselves with this policy and act in accordance with our commitments at all times; undertaking any training that is required of them by the company. • Must escalate any concerns or issues they may perceive to be in breach of this policy to local management or HR swiftly and in confidence; if it doesn’t feel right, tell someone. • Must co-operate with managers in eliminating any risk of modern slavery and human trafficking within our own activities and supply chain. Managers • Have personal responsibility for ensuring this policy is communicated, understood, and applied in their business area; ensuring any relevant training is delivered to all employees within their area of responsibility as required by the company. • Will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to have been mistaken. • Must treat concerns raised by employees seriously, investigating and escalating as appropriate and taking any required action without undue delay. Supply Chain Our supply chain is made up of suppliers, subcontractors, and consultants across multiple categories. They are required to sign up for the Supplier Charter which is aligned to the Responsible Business Charter and includes requirements to commit to compliance with our ethics, anti-bribery and corruption, and modern slavery and anti-discrimination standards. The commitments to us include the supply chain organisation: • conducts its business in a manner that is consistent with the Modern Slavery Act 2015 and fundamental protection of Human Rights which includes implementation of a due diligence procedure for its own supply chain to ensure that there is no forced or compulsory labour, slavery, or human trafficking taking place. • maintains fair competition and avoids complicity in its business practices. • ensures there is full compliance with all relevant legislation relating to equality and diversity, in particular, the Equality Act 2010, and is committed to promoting equality of opportunity and diversity within the organisation and its supply chain. As part of the supply chain management and due diligence requirements the supply chain is committed to transparency and improvement which includes: • Undertaking an annual assessment and participation in any quality, health and safety, and environmental audits to monitor performance, as required. • Compliance with all statutory, regulatory, and company reporting requirements. • Providing information on the provenance of products and being transparent in relation to identification of enterprise risks, processes and working practices

 

This policy will be reviewed regularly to ensure our statements of commitment are appropriate and in line with current legislation. We will also review all other policies that may be of relevance to, or in connection with, this policy to ensure our commitments are sustained.

 

Highfield Management – Updated January 2025