Berry | bpi group respects your privacy and is committed to protecting your personal data.
This policy describes how we collect and use your personal data. It also tells you about your privacy rights.
- Who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Job applicants
- Disclosures of your personal data
- Personal data about others
- International transfers
- Data security
- Data retention
- Your legal rights
This policy was last updated on 22nd May 2018 and historic versions can be obtained by clicking here.
1.Who we are
Berry | bpi group is a trading name of British Polythene Limited, a company registered in England and Wales under company number 350729. This policy also applies to other companies within the same group as British Polythene Limited as follows:
- Flexfilm Limited, a company registered in England and Wales under company number 3379307; and
- Sanders Polyfilms Limited, a company registered in England and Wales under company number 02077853.
The registered office of all companies listed above is Sapphire House, Crown Way, Rushden, Northamptonshire NN10 6FB.
Our contact details are:
|Postal address:||96 Port Glasgow Road, Greenock, PA15 2UL
marked for the attention of Berry | bpi group Data Protection Co-ordinator
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. In the UK this is the Information Commissioner’s Office (ICO) (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.
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 information about you which we have grouped together as follows:
- Identity Data, including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender position, role, company or organisation.
- Contact Data, including contact postal address, email address and telephone numbers.
- Business Data, including data identifying you in relation to our dealings with you or your business as a customer of our goods and/or services or as a supplier of goods and/or services to us. This may include credit rating information (which we acquire from credit reference agencies) and information in relation to the trading accounts between you/your business and us.
- Technical Data that is provided when you access this website, including internet protocol (IP) address, login data, 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 the site.
- Usage Data includes information about how you use our website.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Recruitment Data includes Identity and Contact Data and other information about yourself, skills and experience that you may provide when applying for one of the advertised vacancies, including through the careers section of this website.
Generally we do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. [If however you apply for one of our advertised job vacancies we may ask you to provide equal opportunities information and other information about yourself and health as detailed in section 5.
This website is not intended for children and we do not knowingly collect data relating to children.
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 and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about products or request product information;
- subscribe to our e-updates or publications;
- apply for one of our advertised job vacancies;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Data may also be provided to us by your employer or the company or organisation who is our customer or supplier (see section 7).
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly available sources such as companies registry offices and/or via social media.
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.
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, your employer or business.
- 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 by contacting us click here.
Purposes for which we will use your personal data
We have set out below a description of the ways in which we 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. 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 process and perform any contract between us or your employer or business including:(a) Manage delivery/ receipt of goods and/or services
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(d) Marketing and Communications
|(a) Performance of a contract with you or your employer or business
(b) Necessary to comply with legal or regulatory obligations in relation to retention of business records
(c) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey about customer satisfaction and/or experience
(e) Marketing and Communications
|(a) Performance of a contract with you or your employer or business
(b) Necessary to comply with a legal or regulatory obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you or your employer or business
(b) Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(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 or regulatory obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products and grow our business)|
|To consider and process your job application||(a) Recruitment
(a) Necessary for our legitimate interests (to consider applicants for the job vacancies in our business)
(b) Necessary to comply with our employment law obligations
(c) Performance of a contract with successful applicants
|For more information on Recruitment Data see section 5 click here.|
We seek to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Berry Global, Inc. group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us click here 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, purchase or other transactions.
Change of purpose
We will 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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
This website 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 these third-party websites and are not responsible for their privacy statements.
5. Job applicants
- All of the information you upload through our site in response to any of the advertised job vacancies will only be used for the purpose of progressing your application in accordance with our recruitment procedures, or to fulfil legal or regulatory requirements if necessary. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. We may share the information with other members of our group of companies, including group companies that are based outside of the European Economic Area. We will do this where the application relates to a role with one of our other group companies and/or where the role has any other material connection with other of our group companies. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
- We will use the contact details you provide to us to contact you to progress your application. We will use any other information you provide us to assess your suitability for the role you have applied for which may include shortlisting.
- As part of our recruitment process we may ask you for additional information, including your previous experience, education, mobility and eligibility to work. Our HR team will have access to all of this information.
- You may also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our HR team in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
- Our HR team may shortlist applications for interviews. We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by us.
- If you are unsuccessful following assessment for the position you have applied for, we will retain your details in our talent pool for a period of six months. We would proactively contact you should any further suitable vacancies arise. If you wish not to be considered for any other position, you can specify this on your application or contact us in writing (including via email@example.com) whereupon receipt of your notification all stored information will be destroyed.
- If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff and their right to work in the relevant territory of application. You will therefore be required to provide:
- Proof of your identity – you will be asked to provide copies in advance of employment and on your first day of employment we will ask you to bring the originals for us to confirm.
- Proof of your qualifications – you will be asked to provide copies in advance of your first day of employment.
- We will contact your referees, using the details you provide in your application, directly to obtain references
- We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a third party diagnostics company whose details will be confirmed to you at the time you are asked to complete the questionnaire.If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments
- Emergency contact details – so we know who to contact in case you have an emergency at work
- National insurance
- Date of birth
- Marital status
- Data processors are third parties who provide elements of our recruitment and induction service for us. We will notify you of the identity of any data processor that we share your application and/or recruitment information with.
- If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment and then after your employment in accordance with our retention policy (details of which are available by contacting firstname.lastname@example.org. This includes any employment related declaration you have provided, fitness to work, records of any security checks and references. There is some information we will keep for longer periods in terms of potential claims. If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the advertisement of the relevant position. Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the advertisement of the relevant position.
- Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not. You are able to ask about decisions made about your application by speaking to the relevant contact within our HR team or by emailing email@example.com.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 click here.
- Internal Third Parties as set out in the Glossary click here.
- External Third Parties as set out in the Glossary click here.
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.
7. Personal data about others
In some cases, you may provide personal data to us about other people (such as your customers or employees). You must ensure that you have given those individuals an appropriate notice that you are providing their information to us and have, where appropriate, obtained their consent to that disclosure.
8. International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will 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.
9. 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 process your personal data on our instructions.Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
10.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.Details of retention periods for different aspects of your personal data can be obtained by contacting us click here.In some circumstances you can ask us to delete your data: see Request erasure below for further information.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.
11. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us click here.
No fee usually required
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 these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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.
Time limit to respond
We try to respond to all legitimate requests within one month. 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.
- Glossary Lawful basis
- Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best product and the best and most secure experience. 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).
- Performance of contract means processing your data where it is necessary for the performance of a contract to which you or your employer or business is a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
Internal third parties
Other companies in the same group of companies as British Polythene Limited acting as processors which provide IT and system administration services and undertake corporate reporting.
External third parties
- Suppliers who support our business, including IT and communication suppliers, outsourced business support (including those involved in our recruitment process), marketing and advertising agencies. Our suppliers have to meet minimum standard to information security and they will only be provided data in line with their function.
- Credit reference agencies and / or insurers prior to entering into any contract with you or your business.
- Your company or organisation in relation to us providing goods and/or services to the organisation.
- Market research consultants and marketing agencies involved in our promotional mailings.
- Professional advisers who provide consultancy, banking, legal, insurance and accounting services.
- Third parties in the context of an acquisition or transfer of any part of our business or in connection with a business reorganisation.
- Regulators and other authorities who require reporting of processing activities in certain circumstances.
Your legal rights
To the extent permitted by applicable data protection laws 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. 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 to you. We will advise you if this is the case at the time you withdraw your consent.