PORT AGENCY PRIVACY POLICY

Port Agency Privacy Notice for provision of Client Services

Version: 1.1 August 2018

In connection with your request for MH Bland Port Agency services, MH Bland, as the data controller, will collect and process personal data about yourself, as our client.  Please refer to our website www.MHBland.com and read our organizational privacy statement.  As our client, we ask you to please read this statement carefully to fully understand the process that allows us to provide you with a bespoke service, as requested by you.

Categories of personal data and purposes

We may collect some or all, and process, the following types of personal data to allow us to provide you with our services:

  • Basic details, contact details (email, telephones), passport details and copy, bank account details, location data, Seaman’s book details, travel arrangements and online trends when you visit our website. Sensitive data; criminal convictions (for visa applications), medical and health requirements (disabilities, special support requirements, nature of injuries), under 16’s data (young traveler).

We process the personal data for the following purposes:

  • Comply with our contractual obligation for the provision of your bespoke Port Agency requirements,
  • to provide security assurance and protect your information,
  • handling requests and complaints,
  • to take measures to constantly improve our service to you,
  • investigating and handling queries,
  • following legislative and regulative procedures,
  • handling disputes,
  • settling claims and,
  • interaction with third parties.

Sources

The personal data are collected directly from yourself as our client or indirectly from a representative requesting our services on behalf of an individual/s (data subject).  It is the responsibility of the individual requesting our services, to ensure they have data subject/s consent to transfer this data to us and allow MH Bland to process data for the provision of services.

The legal basis for the collection and processing of the personal data

The legal basis for collection and processing of your personal data is the following:

 

  • 6-1(f) – Legitimate interest (client services),
  • 6-1(c) – Necessary for compliance with legal or regulatory obligations.

When we collect personal data directly from you or indirectly via a representative, you provide the personal data in order to allow us to provision Port Agency services.  You are obliged to provide this information to us, the consequences of not providing this data are that we may not be able to complete arrangements, in full, or partially, dependent on the information withheld.

 

Disclosure of the personal data

The personal data will be disclosed to and shared with, MH Bland and third party services providers in relation to your bespoke requirements.  These are too lengthy to list on this notice so if you require further information please ask for further details.  These include but not limited to:

 

  • Governmental departments,
  • Airlines,
  • Medical services,
  • Ports,
  • Quay services,
  • Dock services,
  • Systems database support,
  • Cloud storage services.

The legal basis for the disclosure of personal data is the following:

  • 6-1(a) –          Consent (will include consent for transfer to third countries and processing of sensitive data),
  • 6-1(c) –         Legal obligation and in compliance with regulations,
  • 6-1(f) –         Legitimate Interest.

Data transferred includes:

  • All or part of the data listed above dependent on source requirement and reason for transfer.
  • Where consent is used, you have the right to withdraw your consent, this will not affect the lawfulness of the processing and disclosure prior to the withdrawal. Please request consent form from our Port Agency Manager.

Transfer of personal data to recipients in countries outside the EU/EEA

Where we transfer the personal data, with your consent, to service providers supporting your request in countries outside the EU/EEA.  It is imperative you note that,

 

The EU Commission has not made a decision on the adequacy of the data protection legislation and practices in such countries.  The legal basis for the international transfer is based on Article 49-1(a) where you have given MH Bland Port Agency, explicit consent to the proposed transfer, after having been informed of the possible risks of such transfer of data due to the absence of an adequacy decision and appropriate safeguards. 

Retention period

We store the personal data for as long as is necessary to fulfil the purposes above, however, for no longer than 5 years after your request for service or, when data is deemed no longer necessary for the purpose of which we based our processing on.

Your rights

Subject to the conditions set out in the applicable data protection legislation, you enjoy the following rights:

 

  • The right to request access to the personal data,
  • The right to rectification of the personal data,
  • The right to erasure of the personal data,
  • The right to restriction of processing,
  • The right to data portability, and,
  • The right to object to processing.

Not all rights listed above are an “absolute right” and MH Bland will consider your request on an individual case by case basis.  You also have the right to lodge a complaint with the competent supervisory authority, the Gibraltar Regulatory Authority (GRA).

Contact

Please contact us at if you have any questions in regards to the protection of your personal data or if you wish to exercise your legal rights.  Address any queries to GDPR@MHBland.com or telephone 200 12790.

Address details: MH Bland Group, Cloister Building, Gibraltar, GX11 1AA

© All rights reserved. MH Bland Group of Companies. 2018

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