Safehinge Primera Limited (“Safehinge Primera”) designs and supplies secure doorsets and door components.  The companies will share personal data between them as required.

Version date: 3 January 2023

1.    Introduction

Safehinge Primera processes personal data relating to our staff and to the staff of our customers. 

This policy sets out Safehinge Primera’s commitment to ensuring that any personal data, including special category personal data, which Safehinge Primera processes is carried out in compliance with Data Protection Law. ‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant UK and EU data protection legislation.

Safehinge Primera ensures that good data protection practice is embedded in the culture of our staff and our organisation. 

We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure. For example, we store the personal information you provide on computer servers with limited access that are located in controlled facilities. Additionally, when we transmit sensitive personal information (such as a credit card number) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.


2.    Scope

This policy applies to all personal data processed by Safehinge Primera and is part of Safehinge Primera’s approach to compliance with Data Protection Law. All Safehinge Primera staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of Safehinge Primera’s data protection policies may also be a criminal offence.


3.    Data protection principles 

Safehinge Primera complies with the Data Protection Principles set out below. When processing personal data it ensures that: 

  • it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); 
  • it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (‘purpose limitation’)
  • it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; (‘data minimisation’)
  • it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
  • it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; (‘storage limitation’)
  • it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

Safehinge Primera will facilitate any request from a data subject who wishes to exercise their rights under Data Protection Law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.  

Safehinge Primera will, in limited circumstances, transfer personal data outwith the UK or EU, for example when engaging the services of automated marketing providers or using cloud customer relationship management systems. Where we do so, we will ensure that the appropriate level of protection required by Data Protection Law is in place.


4.    Process/Procedures/Guidance

Safehinge Primera will:

  • ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law;
  • not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice. 
  • ensure that appropriate privacy notices are in place advising data subjects how and why their data is being processed, and in particular advising data subjects of their rights;
  • only collect and process the personal data that it needs for purposes it has identified in advance;
  • ensure that as far as possible the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible; 
  • only hold onto your personal data for as long as it is required after which time Safehinge Primera will securely erase or delete the personal data;
  • ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely. 

Safehinge Primera will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies; that they are adequately trained; and adequately supervised. 

5.    Data subject rights

Safehinge Primera has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under Data Protection Law. The relevant data subject rights are listed below and fuller policies are available providing detailed guidance on how Safehinge Primera will comply. 

All requests will be considered without undue dealt and within one month of receipt as far as possible.   
Subject access: the right to request information about how personal data is being processed including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information: 

  • the purpose of the processing; 
  • the categories of personal data; 
  • the recipients to whom data has been disclosed or which will be disclosed; 
  • the retention period; 
  • the right to lodge a complaint with the ICO; 
  • the source of the information if not collected direct from the subject; and 
  • the existence of any automated decision making. 

Rectification: the right to have inaccurate personal data concerning them rectified. 

Erasure: the right to have data erased and to have confirmation of erasure, but only where:

  • the data is no longer necessary in relation to the purpose for which it was collected; or
  • where consent is withdrawn; or
  • where there is no legal basis for the processing; or 
  • there is a legal obligation to delete data. 

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:   

  • if the accuracy of the personal data is being contested; or
  • if our processing is unlawful but the data subject does not want it erased; or
  • if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims; or 
  • if the data subject has objected to the processing, pending verification of that objection. 

Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller.  This would only apply if Safehinge Primera was processing the data using consent or on the basis of a contract. 

Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless Safehinge Primera can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.


6.    Special category personal data

This includes the following personal data revealing:

  • Racial or ethnic origin, 
  • Political opinions, 
  • Religious or philosophical beliefs, 
  • Trade union membership, 
  • The processing of genetic data, biometric data for the purpose of uniquely identifying a natural person,
  • Data concerning health,
  • Data concerning a natural person's sex life or sexual orientation, or
  • Data relating to criminal convictions or offences. 

Safehinge Primera processes special category data of employees as is necessary to comply with employment and social security law but does not process special category data of customers, contractors or their staff.


7.    Responsibility for the processing of personal data

Safehinge Primera Limited Board of Directors takes ultimate responsibility for data protection. 

If you have any concerns or wish to exercise any of your rights under the GDPR then you can contact the Data Protection Lead by emailing


8.    Monitoring and review

This policy was last updated on 23 December 2020 and shall be regularly monitored and reviewed, at least every two years.