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Compliance

CF FERTILISERS UK LIMITED

1. PRIVACY NOTICE

CF FERTILISERS UK LTD (“CF FERTILISERS”, WE”, “US”, “OUR”) of Ince, Chester CH2 4LB is a data controller of your personal information. We are committed to protecting your privacy under data protection laws when we process your personal information.

WHO SHOULD READ THIS PRIVACY NOTICE?

This privacy notice applies to all individuals and business related contacts (except our employees, staff and applicants) whose personal information we collect or process. We will use personal information only for the purposes mentioned in this privacy notice.

HOW TO CONTACT US

Any questions regarding our Privacy Policy should be directed to our Data Protection Officer at CF Fertilisers UK Limited at datacontroller@cffertilisers.co.uk or alternatively see the section "Comments" below.

WHAT KINDS OF PERSONAL INFORMATION ABOUT YOU DO WE PROCESS?

We may receive and process the following kinds of personal information about you: title (Mr/Mrs, etc.), full name, job title, work contact details/email, fixed line and mobile phone numbers (work and personal), biodata, personal email, home and business address, delivery addresses/details of end users collected from you as delivery agent or merchant, how you contacted us, online details (mobile phone location data, IP address).

SOURCES OF THIS PERSONAL INFORMATION

We will collect your personal information from you via our website, applications, systems, the telephone, in the usual course of business or (if an end user) from our delivery agents or merchants. In addition, we may obtain your personal information from other sources such as trials, competitions, surveys, events and publically available directories.

WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR PERSONAL INFORMATION?

Data protection laws require us to explain the legal grounds to justify our processing of your personal information. For some processing more than one legal ground may be relevant:

1) Processing necessary for the following legitimate interests:

a) Administering and managing our customer accounts, including contacting contacts’ email/phone to enquire about end users product requirements and deliveries;

b) Replying to questions or other requests for information about our products;

c) To test the performance of our products, services and internal processes;

d) To adhere to guidance and best industry practice;

e) For management and audit of our business operations including accounting and credit issues;

f) To carry out monitoring and to keep records;

g) To administer our good governance requirements;

h) For market research and analysis and developing statistics;

i) To maintain our database of contacts who are our customers;

j) For direct marketing communications (including nutrient management tools);

k) For our profiling and other automated decision making, in particular where this does not have a legal effect or otherwise significantly affect you (we may do this to decide what marketing communications are suitable for you);

l) When we share your personal information with these other people or organisations;

  • Members of our Group;
  • Our legal and other professional advisers;
  • Financial institutions (re: payment of invoices, reimbursements, etc.);
  • Governmental and regulatory bodies (HMRC, the Information Commissioner’s Office];
  • Other organisations and businesses who provide services to us (such as intermediaries and hosting agencies); and
  • Market research organisations and marketing agencies who help us to develop and improve our products and services.

2) Processing necessary to comply with our legal obligations:

a) For compliance with laws and regulations that apply to us;

b) For establishment, defence and enforcement of our legal rights or those of any other member of our Group;

c) For activities relating to the prevention, detection and investigation of crime;

d) To carry out monitoring and to keep records;

e) To deal with requests from you to exercise your rights under data protection laws;

f) To process information about a crime or offence and proceedings related to that; and

g) When we share your personal information with these other people or organisations:

  • Fraud Prevention Agencies;
  • Law enforcement agencies and governmental and regulatory bodies such as HMRC, the Information Commissioner’s Office; and
  • Courts and to other organisations where that is necessary for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.

3) Processing with your consent:

a) When you request that we share your personal information with someone else and consent to that;

b) For some of our profiling and other automated decision making;

C) For some of our processing of special categories of personal data such as about your health or disability access needs (and it will be explained to you when we ask for that explicit consent what purposes, sharing and use it is for.)

HOW AND WHEN CAN YOU WITHDRAW YOUR CONSENT?

Much of what we do with your personal information is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us (see below). The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health or disability access needs (but all of these outcomes described in this paragraph will be relevant only in cases where we rely on explicit consent for this

IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)?

Personal Information is transferred by us to members of our Group who process it and who are based in the US. It may in addition be transferred to other locations outside the EEA for example to our service providers if they or their servers are based there. When your personal information is processed within the EEA then it is protected by European data protection standards. Some countries outside the EEA do not have adequate protection for personal information by law and this includes the US. We will make sure that suitable safeguards are in place before we transfer your personal information to those countries. Safeguards can include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the European Economic Area. Safeguards can also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information

PROFILING AND OTHER AUTOMATED DECISION MAKING

This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, we may do this to decide what marketing communications are suitable for you. We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) where the profiling and other automated decision making does not have a legal or other significant effect on you.

FOR HOW LONG IS YOUR PERSONAL INFORMATION RETAINED BY US?

Unless we explain otherwise to you, we will hold your personal information for the following periods:

  • Retention in case of queries. We will retain the personal information that we need to keep in case of queries from you for seven (7) years, unless we have to keep it for a longer period (see directly below);
  • Retention in case of claims. We will retain the personal information that we need to keep for the period in which you (or the corporate customer) might legally bring claims against us which in practice means seven (7) years, unless we have to keep it for a longer period (see directly below); and
  • Retention in accordance with legal and regulatory requirements. We will retain the personal information that we need to keep even after the relevant contract you have with us has come to an end for ten (10) years and this will be to satisfy our legal and regulatory requirements.

WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAWS?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not. The right of data portability is only relevant from 25th May 2018.

  • The right to be informed about your processing of your personal information;
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
  • The right to object to processing of your personal information;
  • The right to restrict processing of your personal information;
  • The right to have your personal information erased (the “right to be forgotten”);
  • The right to request access to your personal information and to obtain information about how we process it;
  • The right to move, copy or transfer your personal information (“data portability”);
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.

DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.

INFORMATION ABOUT PRODUCTS AND SERVICES

It is very important to us that we provide you with the highest level of service. In order to help us do this, from time to time CF Fertilisers UK Limited may send you details of our products and services which we think may be of interest to you either directly or through our online tools or applications

such as CF N-Programme or Encompass. We may use your home address, phone numbers and email address to contact you according to your marketing preferences to this end. We do this only if we have a legal ground which allows it under data protection laws – in the lists above we set out what is our legal ground for marketing. You can stop our marketing at any time by contacting our Data Protection Officer or by following the instructions on how to do that in the marketing email or other communication. If at any time you do not wish to receive these details, please e-mail us at datacontroller@cffertilisers.co.uk

WHO IS IN OUR GROUP?

As at the date of this privacy notice, the members of our Group are: CF Industries Inc. You should check our website at www.cfindustries.com from time to time in case of any changes to our Group.

ADDITIONAL INFORMATION ABOUT WITH WHOM INFORMATION IS SHARED

CF Fertilisers UK Limited will not share, sell or rent your personal information to third parties. However, we may disclose your personal information to third party suppliers who provide services on our behalf based on the legal grounds for processing guidance set out earlier in this policy.

CF Fertilisers UK Limited may disclose personal information if required to do so by law or if it believes that such action is necessary to protect and defend the rights, property or personal safety of CF Fertilisers UK Limited.

SECURITY

CF Fertilisers UK Limited places a great importance on the security of all information associated with our customers. We have security measures in place to attempt to protect against the loss, misuse and alteration of customer data under our control.

2. Modern Slavery

Compliance Statement Regards Modern Slavery

Introduction

The UK Modern Slavery Act requires large companies (over £36 million UK LIMITED turnover) to set out the steps they have taken to ensure that modern slavery and human trafficking does not take place in its business or supply chain. “Modern Slavery” is a terms used to encompass slavery, forced labour, servitude and child labour. CF FERTILISERS UK LIMITED has a zero tolerance approach to Modern Slavery in our organisation and in our supply chain.

CF FERTILISERS UK LIMITED’s Business and Supply chains

CF FERTILISERS UK LIMITED is a leading supplier of fertiliser, chemicals and utilities in the UK. CF FERTILISERS UK LIMITED’s annual turnover is in excess of the £36 million threshold of the Modern Slavery Act.  CF FERTILISERS UK LIMITED has a diverse supply chain of over 1,000 suppliers covering a wide range of sectoral areas such as utilities, industrial gases, chemicals, packaging, catalysts, equipment and services. The majority of CF FERTILISERS UK LIMITED’s products and services are purchased in the UK and Europe.

CF FERTILISERS UK LIMITED’s Policies

CF FERTILISERS UK LIMITED recognises the importance of putting ethical business conduct at the heart of everything we do. CF FERTILISERS UK LIMITED has a number of relevant policies, including (a) CF Group Code of Corporate Conduct, which outlines our commitment to honesty, integrity, mutual respect and diversity; (b) CF Group Anti-Bribery and Corruption Policy, which is incorporated into CF’s Code of Corporate Conduct; (c) CF FERTILISERS UK LIMITED’s Whistleblowing Policies, which encourage staff to report any wrongdoing which includes human rights violations such as Modern Slavery. CF FERTILISERS UK LIMITED’s initiatives around Modern Slavery will sit alongside these policies.  

Due diligence

CF FERTILISERS UK LIMITED recognises the importance of conducting due diligence on its supply chain. 

For new suppliers, CF FERTILISERS UK LIMITED requires completion of a detailed questionnaire. This questionnaire includes a number of questions specifically related to a new supplier’s practices on Forced Labour, Child Labour, Working Conditions and Freedom of Association, all of which are categories of Modern Slavery.    

For existing suppliers, CF FERTILISERS UK LIMITED has conducted a risk assessment focussing on its largest 100 suppliers. CF FERTILISERS UK LIMITED classified these suppliers into Low-Medium-High risk, using a combination of factors (geographical location, structure of industry, levels of regulation, etc.). CF FERTILISERS UK LIMITED contacted all Medium-High risk suppliers, asking them to confirm their approach towards modern slavery, the steps they have taken to ensure there is no modern slavery in their supply chain, and whether they have a published compliance statement. The responses we have received meet our required standards and the requirements of the Modern Slavery Act.

 Training

CF FERTILISERS UK LIMITED provides training to all employees on CF Code of Corporate Conduct. In addition, CF FERTILISERS UK LIMITED provides training to relevant staff on Modern Slavery within our business and supply chains. All staff are requested to report any suspected cases of Modern Slavery, either in CF FERTILISERS UK LIMITED’s business or supply chains, to CF FERTILISERS UK LIMITED’s Legal and Compliance officers. 

Corporate statement

The Board of CF FERTILISERS UK LIMITED approve this statement which will be reviewed and updated annually. 

3. UK Tax Strategy

View our UK Tax strategy here

Comments

If you have questions, concerns or comments about any aspect of CF Compliance or our Privacy Policy please email them to datacontroller@cffertilisers.co.uk or contact us at:

CF Fertilisers UK Limited,
Ince,
Chester,
Cheshire,
CH2 4LB.
Telephone: 0151 357 2777
Fax: 0151 357 1755