For the purposes of the General Data Protection Regulation (GDPR), Uniglobe Preferred as a trading division of Reed & Mackat Travel Ltd will process your personal data on behalf of your employer. Where travel or associated services are delivered to you as part of an arrangement between your employer and Uniglobe Preferred then, then due our status as an agent, the relevant service provider will be responsible for the security of personal data it received and for compliance with applicable law. Uniglobe Preferred is not responsible for the acts or omissions of such service providers.
The Data Subject’s employer is the Data Controller for these purposes. The Data Controller is the Client Company of Uniglobe Preferred, and Uniglobe Preferred in turn acts as the Processor of the Data Subject’s Personal Data. Pursuant to a written contract with the Data Controller, Uniglobe Preferred as Processor, will use the Personal Data of the Data Subject, provided by the Client Company, to facilitate travel arrangements for the Data Subject. It is this contract of service which forms the ‘Legal Basis’ for the processing of Personal Data carried out by Uniglobe Preferred. (Further information on ‘Legal Basis’ is set out in the appendix to this document.)
There are circumstances where Uniglobe Preferred may also become a Data Controller. If Uniglobe Preferred collects additional Personal Data directly from a Data Subject, Uniglobe Preferred will be acting under a ‘Legitimate Interest’ to legally process the data to facilitate travel arrangements for the Data Subject and to fulfil the contractual requirements for its Client Company. In circumstances where Uniglobe Preferred collects Personal Data from the Data Subject, Uniglobe Preferred will obtain that Data Subject’s express consent. Uniglobe Preferred also acts as a Data Controller for any Personal Data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.
The Personal Data we collect about you will only be the data specifically required to fulfil travel, accommodation, or other travel-related arrangements. Such data may be collected directly from you or provided to Uniglobe Preferred via your employer. Such data will only be processed for that purpose. Certain kinds of Personal Data collected, such as data about your racial or ethnic origin, physical or mental health, or religious beliefs requires additional protection. By providing any sensitive data of this kind you agree that we may collect it and use it to provide our services.
Uniglobe Preferred has adopted the following principles to govern its processing and use of your Personal Data. Uniglobe Preferred is committed to ensuring that the Personal Data collected:
Uniglobe Preferred protects your Personal Data against unauthorised access, unlawful use, accidental loss, corruption or destruction. We use technical measures such as encryption and password protection to protect your data. We also use operational measures to protect the data, for example by restricting access to only those in personnel who need to access your data.
Mindful of technological development, we keep these security measures under review and Uniglobe Preferred may therefore need to implement adequate alternative technical and organisational measures.
As a Data Subject you have the rights set out in chapter 3 GDPR. Uniglobe Preferred will always fully respect your rights regarding the processing of your Personal Data, and has provided below at section 10 the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.
In summary, you are entitled to know who has your Personal Data, what they are using it for, to see copies of all Personal Data held by Uniglobe Preferred and to amend, correct or delete such data. You may also limit, restrict or object to the processing of your data. In each case, the request must be in writing to Uniglobe Preferred using the details set out at section 10 below.
For example, most travel bookings must be made under the traveller’s full name and must include contact details and appropriate identification (e.g. passport details). Uniglobe Preferred cannot make bookings for you without this information.
Transfers to Third Parties
To fulfil your travel arrangements it will in most cases be necessary for Uniglobe Preferred to process Personal Data via a third party (these include but are not limited to airlines, hotels, car hire companies, and Visa or Passport companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the travel arrangements.
Sending data outside of the European Union
Uniglobe Preferred will not transfer Personal Data to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, or is made with your consent, or is made to satisfy the legitimate interest of Uniglobe Preferred in regard to its contractual arrangements with its clients.
All internal group transfers of Personal Data shall be subject to written agreements under Uniglobe Preferred’s Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognised by the European Data Protection Authority.
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You have the right to make a complaint directly to our supervisory authority, the Information Commissioner’s Office at the following address:
England SK9 5AF
To exercise any of your rights, you can send an email to us at firstname.lastname@example.org or you can write to us:
Business Travel Direct
4 Waterside Drive
(Article 4 of the GDPR): means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
(Article 4 of the GDPR): means any operation or set of operations which is performed upon Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.
(Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing Personal Data.
(Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes Personal Data on behalf of the controller.
(Article 6 of the GDPR): At least one of these must apply whenever Personal Data is processed:
Uniglobe Preferred was acquired by Business Travel Direct in 2018 and the Uniglobe Preferred brand is now being retired. Clients will continue to receive the same great service from the same teams - these will now simply operate under the Business Travel Direct brand.
The change will come into full effect from January 1st 2020.