1)     Can I get a more precise time-frame for how long a staff member’s personal data will be stored by Heineken?

The personal data retention periods applicable to learner’s/staff member’s personal data are set out in the learner privacy policy which is available here: https://my.hellobeerapp.com/privacy. The privacy policy that applies to learners using the app (and therefore Topgolf staff) is different from the privacy policy that applies to administrators/pub managers who invite learners. The administrator/pub manager privacy policy is available here: https://hellobeerapp.com/manager/privacy.

 

It has recently come to our attention that the link  to the privacy policy that appears on the ‘Invite a Leaner’ screen on the Hello Beer web platform is redirecting to the administrator/pub manager privacy policy instead of the learner privacy policy. Our software developers are fixing this as a matter of priority. The privacy policy that appears on the app (which is the policy that learners/your staff will see) is correct.

 

2)     When would any personal data collected about Topgolf’s staff be deleted?

As mentioned above, the retention periods applicable to learner’s/staff member’s personal data are set out in the learner privacy policy which is available here: https://my.hellobeerapp.com/privacy.

 

3)     What technical and organisational measures do you have in place for the security of any personal data collected? – I have noted the information is only accessible to Heineken staff on a ‘need-to-know’ basis.

The Hello Beer web platform and mobile application is administered, hosted and maintained by our software development partner, Hello Forward Limited. Hello Forward Limited are obliged to adhere to the attached Information Security Standards.

 

4)     Is any of the data for our purposes exported outside the EEA requiring us to enter in a Data Processing Agreement?

Heineken UK Limited is the data controller in respect of personal data processed in order to provide the Hello Beer app and web platform and we have a Data Processing Agreement in place with our appointed data processor, Hello Forward Limited. This Data Processing Agreement obliges Hello Forward Limited to ensure that no personal data is exported outside the EEA unless the transfer is covered by an adequate transfer mechanism. There is no requirement for Heineken UK and Topgolf to enter into a Data Processing Agreement.


Also see related asana task: https://app.asana.com/0/1183515841815561/1198070155539665/f