Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, 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.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “MSA”) on behalf of The Paperback Shop.co.uk Limited, a company registered in England and Wales with registered company number 3929651 and PBShop.co.uk Limited, a company registered in England and Wales with registered company number 9366362 This statement has been approved by the board of directors.
The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We are committed to acting responsibly and with integrity in all our business relationships and we continue to take measures to implement and enforce effective systems and processes to ensure that modern slavery and human trafficking is not taking place anywhere within our control or influence.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our contractors, suppliers and other business partners will hold their own contractors, suppliers and other business partners to the same high standards.
Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
Compliance with the policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.
This Modern (Anti) Slavery Policy and Statement is intended for businesses in all countries, especially the United Kingdom.
Communication & awareness of this policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
We operate zero tolerance to slavery and human trafficking within our business. We expect all those in our supply chains to comply with our values. We continue to assess our supply contracts by size and risk profile and continue to, wherever possible and commercially viable, purchase goods and services from established suppliers in the UK.
We acknowledge our responsibility to be alert to the risks of modern slavery and human trafficking in our supply chains. We consider the risks in our current supply chains to be low, based on the location of the majority of our suppliers and product/service categories that we purchase.
Nevertheless, we continue to monitor and develop our responsibilities in this regard, as appropriate.
We are committed to the continuous improvement of our knowledge and efforts in eradicating modern slavery.
We are committed to protecting the privacy and security of personal data. This policy tells you how we will collect and use your personal data, and what you should expect in respect of the personal information about you that we have collected.
We are PBShop.co.uk Limited (registered in England & Wales with Company No: 9366362). Our registered office is at Swatton Barn, Badbury, Swindon, SN4 0EU, United Kingdom.
The person with responsibility for our data protection compliance is the Managing Director and they can be contacted via email at help@pbshop.store.
We are the data controller of the personal data that we keep and use, and we are therefore responsible for making sure that our systems, processes and people comply with the relevant data protection laws in respect of that personal data.
We will act in respect of personal data to comply with the six principles of the General Data Protection Regulation (“GDPR”), which are:
You have rights in respect of how your personal data can be processed; these include the right to request:
You have the right to complain to the Information Commissioner, which you can do by contacting the Information Commissioner’s Office (ICO) directly. Full contact details, including a helpline number, can be found on the ICO website (www.ico.org.uk). This website also has useful information on your rights and our obligations. However, please raise any concerns or issues with us first so that we may deal with this as quickly as possible for you.
We collect and process data for the following reasons:
All of our people are required to abide by our Privacy Policy when handling personal data, and are provided with appropriate data protection training. Any breach of data protection will be taken seriously, and may result in disciplinary action.
Collection:
We will collect personal information which may include names, addresses and other information for our customers. This will be done for the management of the commercial relationship with our customers.
We may collect this personal data from you directly, and also from third parties, including publicly available third party sources. Additional personal data will be collected as it is created by or supplied to us in the course of anything we do for you.
Use:
We will use the personal data in the course of making sales and to comply with requirements that we are required to undertake.
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:
We may also use your personal data in the following situations, which are likely to be far less common:
Disclosure:
We may share personal data with third parties as is necessary in the sale of books and other items, including to third party providers who deliver services to support the operation of our company.
In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.
Retention Period:
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Normally, our retention period for personal data collected for this purpose is a minimum of 6 years after the end of the period that we are selling books and other items.
Collection:
We will collect names, addresses, contact details, education and employment history, identity and other background checks (which may include appropriate criminal and financial checks and confirmation of the right to work in the UK), marital status and information on next of kin and dependents, financial information (such as bank details and NI numbers), date of birth, gender, a copy of your passport and driving licence, performance information and compensation history, recruitment information (including references), salary, benefits, pension and annual leave information, disciplinary and grievance information, photographs, information about your use of our information and communications systems and CCTV footage or other information obtained through electronic means.
We may collect and use special categories of personal data as required in the carrying out of obligations and exercising specific rights of us or the data subject in the field of employment. This may include information relating to matters such as health, racial origin, religious belief and offences or alleged offences.
Personal data may be collected from you during the selection process (for example via your application form and CV) and during your employment (including holiday forms, expense claims, performance reviews, any disciplinary or grievance processes), or from third parties, including referees, health service providers, background check providers.
Use:
Personal data of our people will be used for HR administration and management, both in respect of the selection of people to work for us (including suitability, eligibility and/or fitness to work), and those who do work for us, to include learning and development, disciplinary and security (of people, offices and data) requirements, providing and liaising with benefits providers, business management and planning (including accounting and auditing), paying you and dealing with tax and NI deductions, assessing and deciding on salary reviews and compensation, conducting performance reviews and managing performance, dealing with legal disputes involving you or others, preventing fraud, monitoring your use of our information and communications systems, ensuring compliance with our policies, and equal opportunities monitoring.
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:
We may also use your personal data in the following situations, which are likely to be less common:
In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.
In respect of special categories of personal data, we may process this in the following circumstances:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your (or someone else’s) interests and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about our people (or former people) in the course of our legitimate business activities with the appropriate safeguards.
The special categories of personal data may be used in the following ways:
Disclosure:
Personal data may be transferred to service providers who support the operation of our business (such as payroll service providers), to other third parties reasonably necessary in the conduct of our business (including insurers, professional advisors, regulators). These third parties may be acting as processor, or controller of personal data in their own right.
In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where we have another legitimate interest in doing so, and we will ensure that the personal data is appropriately protected.
Retention Period:
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. We will normally keep personal data of applicants who we do not employ for six months after we receive it.
We will keep personal data of employees throughout your employment and normally for a minimum of six years after your employment ends.
It is very important that the personal information that we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.
We have put in place 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 of our people and other third parties who have a business need to know. They will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and the ICO of a suspected breach where we are legally required to do so.
We principally store data, both electronically and on file, at our office.
Personal data may be transferred outside of the EEA by processors acting on our behalf. For transfers to countries not considered adequate by the EC, we will ensure that personal data is adequately protected, as required by the GDPR. This would include by use of the Standard Contractual Clauses adopted by the EC to protect personal data.
Under certain circumstances, you have the right by law to request:
Our website may, from time to time, contain links to and from the websites of third parties that we permit to make such links. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal data to these websites.
Any changes we may make to our privacy policy in the future will be posted on our website, so please ensure that you are viewing the correct version.
Please contact us if you have any questions, comments or requests regarding this Privacy Policy.
Last amended May 2021.