PROTECTING YOUR PRIVACY
JOHN LEWIS PARTNERSHIP
CONTENTS OF PRIVACY NOTICE
- What is The John Lewis Partnership?
- Explaining the legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- Combining your data for personalised direct marketing
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- John Lewis Finance
14.1 How we use your personal data
14.2 How our providers use your personal data
14.3 Joint use of your personal data
- Contacting the Regulator
- If you live outside the UK
- Any questions?
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how the John Lewis Partnership uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across the John Lewis Partnership to build a picture of you.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
When you are using the John Lewis websites, John Lewis plc is the data controller.
2. What is The John Lewis Partnership?
The John Lewis Partnership – which we’ll refer to as ‘the Partnership’ in this document – is made up of a number of related businesses:
- John Lewis plc – including John Lewis Finance (provided by selected partners), John Lewis The Gift List, Home Solutions, my John Lewis loyalty, joint loyalty membership and John Lewis for Business.
- You can find out more about how John Lewis Finance handles your personal in section 14.
- Waitrose ltd – including myWaitrose loyalty, waitrose.com, waitrosepet.com, waitrosegarden.com, waitroseflorist.com, waitrosecellar.com, waitrosegifts.com, Cook Well from Waitrose, the Good Food Guide, Waitrose & Partners Cookery School, Leckford Estate (The Waitrose & Partners Farm).
- John Lewis & Partners International – if you’re based outside the UK and order from us, you will be trading with John Lewis & Partners International Ltd. This Privacy Notice applies to international orders, but there are additional terms for certain countries which supplement this notice and take priority over any conflicting provisions. You'll find more information in section 16.
For simplicity throughout this notice, ‘we’ and ‘us’ means the Partnership and its brands.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
If the law requires us to, we may need to collect and process your data.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
4. When do we collect your personal data?
- When you visit any of our websites, and use your account to buy products and services, or redeem vouchers from the Partnership on the phone, in a shop or online.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you purchase a product or service in store or by phone but don’t have (or don’t use) an account.
- When you engage with us on social media.
- When you download or install one of our apps.
- When you join a Partnership loyalty programme (such as my John Lewis, myWaitrose or joint loyalty membership).
- When you purchase foreign currency from us we'll collect personal information such as your name, address and proof of identity.
- When you sign up to my John Lewis or joint loyalty membership, you will be given access to an area on johnlewis.com called Kitchen Drawer. This will collect and store all of your receipts, guarantees and warranties for you when you make a purchase from John Lewis & Partners shops and johnlewis.com.
- When you contact us by any means with queries, complaints etc.
- When you ask one of our Partners to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event, for example a class at Waitrose & Partners Cookery School.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
- When you fill in any forms. For example, if an accident happens in store, a Partner may collect your personal data.
- When you’ve given a third party permission to share with us the information they hold about you.
- When our John Lewis Finance suppliers and partners – such as HSBC or RSA – share information with us about the product you have purchased.
- We collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.
- When you use our car parks and shops which usually have CCTV systems operated for the security of both customers and Partners. These systems may record your image during your visit.
5. What sort of personal data do we collect?
- If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
- Details of your interactions with us through contact centres, in store, online or by using one of our apps.
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your shopping preferences.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and product reviews.
- Your image may be recorded on CCTV when you visit a shop or car park.
- Your car number plate may be recorded at some of our car parks to manage parking restrictions.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Learn more about this.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
6. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
- To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our stores and car parks which record images for security. We do this on the basis of our legitimate business interests.
- We manage our car parks in conjunction with Britannia Parking (opens in a new window; please note we can't be responsible for the content of external websites)
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across the Partnership, third parties and data from publicly-available lists as we have described in the section 'What Sort of Personal Data do we collect?' We’ll do this on the basis of our legitimate business interest.
- For my John Lewis or joint loyalty members, to decide which information to show you, with the help of computer algorithms. We do so on the basis of your consent when you become a my John Lewis or joint loyalty member. If you don’t want to continue receiving my John Lewis offers, you’ll be unable to continue your my John Lewis or joint loyalty membership.
- To process your booking/appointment requests (for example with a personal stylist). Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers or a fitter visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
Here’s more information on how we share personal data with third parties.
- For myWaitrose or joint loyalty cardholders: to provide you with tailored offers, printed with your till receipt at the end of a shopping trip. These are based on an analysis of previous purchases using your myWaitrose card, including the items you’ve just bought. We do this on the basis of our legitimate interest to show you relevant offers. Of course, you’re free to choose whether to take advantage of them.
7. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the Partnership as described above, for example your shopping history at both John Lewis & Partners and Waitrose & Partners. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the Land Registry mentioned above.
8. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
10. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell the Partnership and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
- For further information please contact our Data Protection Officer.
To help personalise your journey through Partnership websites we currently use the following companies, who will process your personal data as part of their contracts with us:
- Adobe Dynamic Tag Management
- Adobe Scene7
- New Relic
- Infectious Media
- Session Cam
- Visual IQ
- Adobe Analytics
- AWIN (Affiliate Window)
11. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the Partnership in the UK.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
12. What are your rights over your personal data?
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
- Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
- That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a Partner of any decision made based solely on automatic processing of your data (so where no human has yet reviewed the outcome and criteria for the decision).
- You can contact us to request to exercise these rights at any time by completing an online form.
- If we choose not to action your request, we will explain the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of an extended warranty.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account, log in into your johnlewis.com or waitrose.com account, visit the ‘My Account’ area and change your preferences.
- In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
- Write to Group Customer Insight (Customer Data), Partnership House, 1st Floor, Carlisle Place, London SW1P 1BX.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
14. John Lewis Finance
14.1 How we use your personal data
When you purchase a product or service from John Lewis Finance, we might receive a copy of the information you supplied. If you agree to receive marketing communications from us, we will use your data to personalise what we send you. You are free to opt out of receiving marketing communications from us at any time.
Find out more about the use of your data for marketing in section 7.
14.2 How our providers use your personal data
When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.
Here are those individual privacy policies (all links open in a new window; please note we can't be responsible for the content of external websites):
- Partnership Card provided by HSBC
- Home Insurance provided by RSA
- Specialist Home Insurance provided by Covea
- Pet Insurance provided by RSA
- Wedding and Event Insurance provided by RSA
- Car Insurance provided by Ageas
- Travel Insurance provided by Ageas
- Interest Free Credit provided By Hitachi
- Payment Plan provided by Hitachi
- Foreign Exchange provided by First Rate
- International payment provided by HiFX (PDF)
- Money Transfers provided by Western Union
- Kitchen Finance provided by Hitachi
- Personal Loans provided by HSBC
14.3 Joint use of your personal data
We will share data with our providers to bring you relevant offers, updates, products and services, and discounts that reward your loyalty to our brands.
We may check your details with appropriate third parties (for example credit reference agencies, such as Experian) before we send you promotions for our financial services products, to ensure your information is accurate and fulfils our legal and regulatory obligations, and to tailor those offers to you.
Rest assured that all applications for financial services products will be assessed on a case-by-case basis.
15. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
16. If you live outside the UK
For all non-UK customers
This Privacy Notice shall be provided in English, French, Spanish, Portuguese, Malay and Chinese languages. Should there be any conflict in the meanings between the English and translated version, the English version shall prevail. copies of foreign language versions are available from our Customer Services team.
By placing an order with the Partnership, browsing our website, including for
analytics and website usage research, and/or agreeing to receive direct
marketing electronic communications as described in this Privacy Notice and our
Cookies Notice, you expressly consent to the processing of your personal data
by us or on behalf of us. Of course, you still have the right to ask us not to
process your data in these ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you have requested. In the ordinary course of business, we may transfer your personal data to third parties located in the UK to your country of residence. You hereby expressly consent to such overseas use, transferring and disclosure of your personal data outside of your country of residence for such purposes.
We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of your country of residence shall not use your personal data other than for that part of the purposes as set out in this Privacy Notice and to adequately protect the confidentiality and privacy of your personal data.
We will ensure that any third parties only process your personal data in accordance with their legitimate interests. These third parties may be subject to laws that differ from the laws which apply in the country where you reside.
We do not actively take steps to ensure that any overseas recipient of
your personal data complies with the laws which apply in your country.
If you have any questions, please contact our Data Protection Officer, and we will respond within your local timeframe response requirements. To complain about an alleged breach of this Privacy Notice or our privacy obligations at law, please provide us with as much detail as possible in relation to your complaint. We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.
For the purposes of this Privacy Notice, “personal data” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, or opinion is recorded in a material form.
We are committed to keeping your personal information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
If you are in Australia, you may submit a complaint to our Data Protection Officer
who will come back to you within 30 days. If we have not come back to you or
you are not happy with the response that you receive you may submit a complaint to the Office of the Australian Information Commissioner.
To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Notice.
If you submit a request to stop direct marketing communications from us, it will
take no longer than 10 days.
As your data may be transferred to third parties outside the country where you are located, local police or other enforcement, regulatory or Government bodies may have access to that data with or without the Partnership’s knowledge. The personal data we process may be accessed by persons within the Partnership, or our third party service providers, who require such access to carry out the purposes indicated in this Privacy Notice, or such other purposes as may be permitted or required by the applicable law. Personal data we collect is maintained primarily in the UK.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.
Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data (Privacy) Ordinance (the “PDPO”).
Under the Personal Data (Privacy) Ordinance (the “PDPO”), individuals must be notified at the point of collection of the purposes for which the data was collected and thereafter the data can only be used for those purposes unless consent is obtained for a new purpose.
If you are in Hong Kong you may submit a complaint to our Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.
Terms used in this Privacy Notice shall have the same meanings ascribed to them in the Personal Data Protection Act 2010 (“PDPA”).
If you are in Malaysia you may submit any questions, comments or complaints to our Data Protection Officer who will come back to you within 21 days.
The transfer of data to enable the company to supply the goods or services a customer has requested can be deemed as a Delegation.
Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).
By placing an order with us, opening an account, browsing our website and/or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.
17. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at DPO@johnlewis.co.uk
- Or write to us at Data Protection Officer, Partnership House 1st Floor, Carlisle Place, London SW1P 1BX
This notice was last updated on 16/10/2018