PRIVACY NOTICE (GROUP)

This privacy notice (privacy notice) is operated by Dale Farm Limited on behalf of itself and its group (being any subsidiary or holding entity from time to time of Dale Farm Limited and any subsidiary from time to time of a holding entity of Dale Farm Limited) (we, us or our).

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us. This may include (without limitation) when you engage with us as an actual or potential member, customer or supplier (or as an employee or representative of either), visit our premises, interact with us in relation to our goods or services, take part in a competition or survey, apply for a job with us (or you are named in a job applicant’s recruitment documents), or visit and use our websites (Site).

This notice also informs you how we will look after your personal data when it is in our control, and about your privacy rights and how the law protects you. It does not cover any website you have used to access our Site or any website that you access from our Site.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.

1. WHO WE ARE

Under the UK General Data Protection Regulation and other relevant data protection legislation, we act as a data “controller” in relation to any of your personal data that we collect and receive. If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact us using the details set out below.

Contact Details

Our full details are:

Full Name of Legal Entity: Dale Farm Limited, company number NI025356

Email Address: privacy@dalefarm.co.uk

Postal Address: Dale Farm House, 15 Dargan Road, Belfast BT3 9LS, Northern Ireland

ICO Registration Number: Z836823X

Changes

This privacy notice was last updated in December 2024. We reserve the right to vary the terms of this privacy notice from time to time. Any material changes to this privacy notice will be made available by updating the document at https://dalefarm.com/privacy-policy. Where necessary, we may contact you directly to inform you of the updates.

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.

Third-Party Links

Our Site 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 any such third-party websites and are not responsible for their privacy notices. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

2. 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 as set out below.

Data that you directly supply to us

• General Personal Data – this is personal data about you that you share with us by online forms on our Site, through email, through the post, on the telephone or by any other means. Typically, when you deal with us you may provide information about yourself or your business, including your name, job title, address, business name, personal and/or business email address, telephone and/or mobile phone number and other contact details, documentation confirming your identity, such as your passport or driving licence (if required), details of your visits to Dale Farm Group’s premises (including your vehicle registration number) and your correspondence, communications and connections with our staff, publicly available information and any other information which is provided to us by you or on your behalf. You may provide similar information where you contact us or sign up to our newsletter or other marketing emails. You may also communicate your preferences in receiving marketing from us and third-parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
• Financial Data – we do not typically collect or hold your financial details, save where you have provided us with these in order to facilitate payments. This is likely to include bank account and payment card details, as well as information about past-payments.
• Employment Data - data which may be provided to us during a recruitment campaign, such as the data which is included on your CV, covering letters and on any responses to job applications and selection processes, documentation confirming your identity, such as your passport or driving licence (if required), details of your visits to Dale Farm Group’s premises and your correspondence, communications and connections with our staff, Equal Opportunities information as required by NI and GB law, publicly available information and any other information which is provided to us by you or on your behalf.
• Health Data – data which relates to your health, which you provide to us to allow us to make reasonable adjustments to facilitate your attendance at our sites and locations or we collected through risk assessments or incident reports;
• Marketing and Communications Data - your preferences in receiving marketing from us and our third parties and your communication preferences.
• Contact Data – should you contact us regarding any issue (in writing, by phone or in person), information arising from that contact shall be collected, including relevant notes about the issue and how we responded to the issue.
• Third-Party Personal Data – where you share personal data that do not relate to you, you must ensure you have the consent to do so and have shared this privacy notice with such person(s).

Data that we collect

• Technical Data – we may use certain technical services to gather technical data online whenever you use our Site, including information relating to your interaction with the Site (such as access times), internet protocol (IP) address, your 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 Site.
• Call Recordings – conversations (through online meeting calls) may be recorded to improve training, to ensure a high level of consistent customer service, or otherwise as required in our legitimate interests or to process contracts we have with you or your business.
• CCTV Footage – we may use CCTV cameras on our premises and/or dashcams on our vehicles, which may record footage of you where you attend our premises in person, and use such footage as required in our legitimate interests, including to ensure the security, safety and well-being of our staff and assets and to take and/or defend criminal and civil legal actions.

Information we receive from third parties

• General Personal Data - this is the same information as described above, but we may sometimes receive that data from third parties like job candidates who have listed you as a reference.
• Social Media Data – where you have contacted or responded to us through any social media channel, we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information will be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given consent to do so.
• Employment Data – this is the same information as described above, but we may sometimes receive that data from third parties like recruitment agencies, your referees or your previous employers.
• Publicly Available Information – we may collect personal information about you from publicly available sources. This can include your name, address and other publicly available information. This may include credit reference agencies such as Experian, public registers such as the Companies House registry or the Electoral Register.

We may 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 feature on our Site. 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 notice.

Other than Employment Data, Health Data and where you provide it to us, we do not regularly collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data or information on your criminal convictions and offences).

3. HOW WE USE YOUR PERSONAL DATA

We use different methods to collect personal data from and about you. The ways we collect it, what we collect, the applicable basis on which we may rely (depending on the actual usage of the personal data), and how and why we use that personal data is set out below:

Personal Data Type	Collection Method	Basis of Use	Purposes
In relation to Members
General Personal Data Financial Data	Directly from Member (or from referrer) Legitimate interests (to run our company)		To manage membership of the Dale Farm Co-operative (including sharing with other Members when appropriate, such as in relation to election processes) To run, analyse and report on surveys
Contact before and during a contractual relationship with you or a party to whom you are affiliated or related, or when you interact with our staff
General Personal Data Contact Data Financial Data Social Media Data Publicly Available Information	Interactions instigated by you (including through social media, email, our Site and our telephone lines) Data capture forms Through entering competitions and promotions and participating in surveys From companies we have bought (in whole or in part)	Consent Contract Legitimate Interests (to run our company) Lawful obligation	To contact you and dealing with your queries To register you or a third party (like your employer) as a customer or supplier and manage relationship To analyse and improve relationships and interactions To perform a contract we have entered into with you or a third party (like your employer) To make our products and services available To manage payments and charges To manage competitions To run, analyse and report on surveys To provide billing information to you Collecting and recovering money owed to us To deal with additional legal obligations
Health Data you or a third party (like your employer) Legitimate Interests (to run our company) Lawful obligation			To control access to site for specific purposes To carry out and maintain suitable Risk Assessment and method statements To ensure your safety and security when carrying out services at our sites or for us In connection with any risk assessments and incidents To assist in taking or defending against any criminal or civil disputes or litigation.
General Personal Data Financial Data Marketing and Communications Data	From third parties like social media companies, advertising networks, electronic payment providers, data aggregators or your employer Consent Contract Legitimate Interests (to run our company) To deliver our goods / services To receive goods / services To occasionally provide marketing content
Whenever you interact with our Site or tracked emails
Technical Data Usage Data Marketing and Communications Data	Interaction with Site use of cookies Legitimate interests (to administer our IT systems) Legitimate interests (to place cookies in accordance with our cookie policy, where consent is not required) To permit access to our Site To keep our online avenues working, up to date and effective To monitor, analyse and use metrics such as numbers of visitors, traffic data and demographic patterns; To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) To protect the security and integrity of our online platforms, IT systems and other systems To deliver our Site content to you, measure Site traffic, measure user interests and traffic patterns, and improve our Site and the services and features offered via our Site As otherwise described in our Cookie Policy Marketing and Communications Data
	use of cookies and cookie management banner	Consent	To customise features and advertising that appear on our Site As otherwise described in our Cookie Policy
Whenever you apply or someone else applies for a job with us
General Personal Data Health Data Employment Data Third-Party Personal Data From you or recruitment agencies Contract Legitimate Interests Legal obligation To manage recruitment, selection and employment (including making reasonable adjustments)
General Personal Data From you or third parties like job candidates Legitimate Interests To manage recruitment processes and selection and employment decisions
Whenever you visit a location or interact with certain equipment we control
General Personal Data CCTV Data Health data CCTV systems (including dashcams) From you or a person with whom you are affiliated Legitimate Interests (for security, health and safety and in connection with legal claims and disputes) To prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime; For the personal safety of our and our customers’ staff and 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; To assist in day-to-day management, including ensuring the health and safety of staff and others (e.g. to manage evacuation requirements) and detecting any non or poor performance of job duties; To assist in the effective resolution of disputes; and To assist in taking or defending against any criminal or civil disputes or litigation.
Ancillary processing
any of the above as above Legitimate interests (to protect and run our company) Compliance with law To anonymise and aggregate so that your information is no longer personal data and can be used outside as described in this Processing Notice Ancillary purposes, such as back-ups and archiving Dealing with legal obligations (such as compliance with tax law, identity verification requirements and preparing company accounts) and disputes

NOTE: 

We may process your personal data on more than one lawful ground, depending on the specific purpose for which we are using your data.

Please note that the above lists are non-exhaustive. We will generally only use your Personal Data for the purposes for which we collected it, unless permitted by law or we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated and incompatible purpose, we will notify you where necessary and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Legitimate Interest

Where used in the table above, “Legitimate Interest” can mean our interest or the interest of another party. 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). Where we rely on legitimate interest, you can contact us for more details on the consideration of these interests.

Consent

Whenever we rely on your consent (as noted above), you have the right to revoke such consent at any time by emailing privacy@dalefarm.co.uk. Unless another basis of use exists, we will collect your consent to use your personal data for our marketing and remarketing purposes generally by using tickboxes or where your actions clearly demonstrate your consent (such as by providing your contact details for a specified purpose).

Marketing

We may use your 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).

If you are or have been a customer of ours, we may contact you from time to time by call or email to provide some information about our products or services. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase or other transactions.

We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing unrelated to our company.

Legal Requirements

We will process your data pursuant to any legal or regulatory requirements imposed upon us and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts. By way of further example, we will share your personal data with relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the categories of processors or controllers set out below (all established in the UK or EEA unless otherwise stated) for the purposes set out in in section 3 above or otherwise below:

• with other members of our groups of companies and related entities (like company reps);
• with HM Revenue & Customs, regulators and other authorities based in the United Kingdom or Ireland who require reporting of processing activities in certain circumstances (such as HSENI);
• with third party purchasers (and their advisors), if we buy, sell or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement. 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 and it is those new owners who shall retain responsibility for their use of your personal data;
• with selected third parties for performance of our contracts with you and to facilitate contact (such as recruitment platforms, social media platforms);
• with specific selected third parties, determined by us, in entering into or if any agreement between you and us is actually or allegedly breached or may come to an end (including so as to enforce or defend our rights), credit-reference agencies, debt-collection firms or service providers, insurers and/or brokers, solicitors or barristers and law enforcement agencies (if applicable);
• with service providers acting as processors who provide the following services: IT and system administration and security; email marketing; survey facilitation; data analytics; cloud storage; data storage and archiving; data destruction; milk analysis and payment processing software; digital signature providers; ordering platforms; and

• other parties where you ask us to share that data, or we ask you and you consent.

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 the minimal personal data required for the specified purposes and in accordance with our instructions.

In addition to the specific disclosures of personal data set out in this section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We may also disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. In complying with court orders and similar legal processes, we strive for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.

5. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK other than to the European Economic Area (EEA). If and when we do, we will ensure that a similar degree of protection is enforced as is required within the UK by ensuring that the recipients use and are bound by standard contractual clauses which may be enforceable by you regarding data protection (as well applying appropriate additional security measures), or the recipient countries have been deemed to provide an adequate level of protection by the UK.

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.

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.

Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our Site, and before it reaches us, such data is transmitted at your own risk.

7. DATA RETENTION

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.

To understand the retention schedules which apply to your personal data, please contact us using the details above. In summary of the retention schedules which will be of most interest, we will delete or destroy personal data within a reasonable time after expiry of the following (unless we have reason to retain your personal data for longer):

• information related to your registration as a user of our app: 6 years after your last login;
• information related to Members: 7 years after membership ends;
• information related to interactions with our suppliers and customers: 7 years after contract conclusion (other than bank details, which are retained for 6 months post-agreement, and silage samples which are retained for 2 years);
• contractor induction data: 3 years;
• competition and survey participants: 12 months;#
• health reports: usually 4 years;
• if you are successful in your job application, you will be provided with a staff Processing Notice which will provide further detail in relation to how your data will be used. If you are unsuccessful, we will delete your Employment Data and application 24 months after the decision is made;
• whenever you visit a location or interact with certain equipment we control: 3 years; and
• CCTV and dashcam information is usually retained for 30 days after collection.

Ancillary processing

In 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.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• 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. Please 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.

If you wish to exercise any of the rights set out above, you can make a Subject Data Access Request by contacting Privacy@dalefarm.co.uk clearly outlining:

• the nature of the request (e.g. access to data, erasure of data, correction etc.); and
• clearly outline what time periods the request relates to.

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 such circumstances.

Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.

We try to respond to all legitimate requests within 30 days. 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.

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). However, we would welcome the chance to deal with your concerns before you approach the ICO so would ask that you please contact us in the first instance.

9. LAW & JURISDICTION

Save only where and to the extent otherwise required by local law, this privacy notice shall be governed by and interpreted in accordance with the laws of Northern Ireland and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this privacy notice.