Modern Slavery Statement
BAMFORD COLLECTION MODERN SLAVERY STATEMENT FOR 2023
This statement is published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Bamford Collection and its subsidiaries (Daylesford Organic, Bamford, and The Daylesford Stays) during the year ended 31st December 2023.
INTRODUCTION
Slavery, servitude, forced labour and human trafficking (Modern Slavery) is prevalent across the world today. It is important that businesses do not deny or try to ignore this problem. Bamford Collection has a zero tolerance approach to Modern Slavery within our operations and supply chain and we are committed to ensuring that this approach is effective.
BAMFORD COLLECTION'S BUSINESS
Bamford Collection is a group of businesses dedicated to sustainable, organic, and ethical practices across various sectors:
- Daylesford Organic: An organic farm and retail business, its activities include online sales of goods and events, and the operation of farm shops and cafes.
- Bamford: A lifestyle brand offering clothing, skincare, and wellness products made with natural and organic ingredients. Its activities include online sales of goods and services, the operation of stores selling clothing and bath and body products, The Club by Bamford, and directly owned spas.
- The Daylesford Stays: A collection of cottages and farm stay accommodations, offering sustainable eco-retreats. Its activities include food and beverage sales, accommodation and events.
EMPLOYEE POLICIES
Bamford Collection maintains comprehensive policies to prevent Modern Slavery and protect workers' rights. These include fair employment contracts, regulated working hours, non-discrimination practices, freedom of association, and strict prohibitions on forced labour and child labour.
We provide safe working environments, offer grievance mechanisms, and conduct right-to-work checks. Regular training ensures employees understand their rights and can report concerns without fear of reprisal. These policies apply across all Bamford Collection entities and are regularly reviewed for effectiveness.
SUPPLY CHAIN
The supply chains for our diverse businesses involve multiple tiers, from raw material sourcing to final product delivery. While this complexity presents challenges in managing Modern Slavery risks throughout the entire supply chain, we focus on actively managing our Tier 1 (direct) suppliers and using them as a conduit to communicate our expectations down through the supply chain.
Our suppliers span various industries, including agriculture, textiles, cosmetics, and hospitality. The majority of our suppliers are based in the United Kingdom and Europe, with some international suppliers for specific products or ingredients.
SUPPLIER ADHERENCE TO BAMFORD COLLECTION VALUES & ETHICS
Before appointing any supplier, Bamford Collection undertakes a comprehensive review of their commercial, financial, and ethical standing. This process includes an assessment of their labour practices and commitment to human rights.
SUPPLIER CODE OF CONDUCT
We have implemented a Supplier Code of Conduct that clearly communicates our social standards and business ethics to our supply chain. This code includes specific requirements directly relevant to preventing Modern Slavery within our suppliers' businesses.
Acceptance of our Supplier Code of Conduct is mandatory for all suppliers doing business with Bamford Collection. All new and existing suppliers are required to sign and adhere to this document.
CONTRACTUAL CONTROLS
Our standard Terms and Conditions of Purchase include dedicated clauses on Human Rights, Modern Slavery & Labour Law compliance. These clauses contractually oblige our suppliers to ensure Modern Slavery is not occurring in their business and to implement due diligence procedures for their own suppliers.
DUE DILIGENCE PROCESSES FOR MODERN SLAVERY
We evaluate our suppliers across quality, ethics, and risk metrics. Key aspects of our due diligence process include:
- Supplier Engagement and Accountability: All suppliers must accept our Supplier Code of Conduct, which explicitly prohibits Modern Slavery. Our standard Terms and Conditions include Human Rights and Modern Slavery compliance clauses. We require suppliers to implement management systems ensuring conformance to all requirements and to provide clear information about their production methods and supply chain.
- Risk Assessment and Auditing: We regularly assess our supply chain to identify high-risk areas, considering factors such as geographical location and industry sector. We conduct on-site audits of suppliers to verify compliance with our Code of Conduct, with a focus on labour practices and traceability of materials and products.
- Continuous Monitoring and Improvement: We monitor supplier compliance on an ongoing basis, tracking issues identified through our auditing processes. When non-conformities are found, we work with suppliers to develop and implement corrective action plans, prioritizing remediation over disengagement.
- Grievance Mechanisms and Transparency: We require our suppliers to maintain accessible grievance mechanisms for workers, their representatives, and the community. We are committed to transparency in our anti-slavery efforts and continuously improve our due diligence processes to enhance their effectiveness in combating Modern Slavery.
FURTHER STEPS
Bamford Collection continues to work with our suppliers to increase supply chain transparency and more specifically in relation to ensuring Modern Slavery is not taking place within its supply chain.
Signed by Nick Fletcher, Chief Executive Officer of Bamford Collection
Bamford Limited is committed to protecting your personal information and complying with the General Data Protection Regulations (GDPR). This policy describes how we collect, use, store and disclose your personal information.
Bamford Limited (“Bamford”) is the lead data controller in respect of personal data processed under this policy. Bamford Limited’s company number is 04950734 and registered address is 19 Mossop Street, London SW3 2LY.
This policy applies to any personal information provided by you through the Bamford or Bamford Grooming Department websites (www.bamford.com or www.bamford.co.uk or www.bamfordgroomingdepartment.com) or through your interactions with us through Bamford or Bamford Grooming Department stores or spas.
It is important that you read this privacy policy together with any other privacy policy Bamford may provide on specific occasions from time to time when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This policy supplements any such other policies and is not intended to override them.
Why do we collect personal information about you?
Bamford collects personal information about you to inform you about, and provide you with, Bamford Products or services, to deal with any enquiries you may have about them and to improve and develop these and the site for the future.
What Personal Information do we collect?
Bamford collects the following types of personal information about you:
– Identity data – Forename and surname, Company name (if relevant), gender, marital and family status (if you make this known to us in our dealings), birthday.
– Contact data – E-mail address, Telephone number, Address, Delivery name and address.
– Transaction data – Details of the Bamford Products or Service you have purchased from us and information about whether or not payment has been made.
– Profile data such as log-in information, purchases made or treatments booked by you, your interests and preferences and any feedback and survey responses.
Marketing and communications data such as your preferences in receiving marketing from us and your communication preferences.
We do collect health information about you (which is a Special Category of Personal Data) with your consent when you attend for spa treatments at a Bamford spa as this is necessary to protect your vital interests to ensure that we provide you with a suitable treatment taking into account your health. You have the right to object to providing such health information but we may not be able to provide you with our services or may provide you with
Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services. For example, if you’re using the site on your mobile, you may choose to provide us with location data. The information we obtain from those services does depend on your settings for that service or their privacy policies. So you should always regularly check what those are.
With regard to each of your and your authorised users visits to our site we may automatically collect the following information:
– Technical information, including the Internet protocol (IP) address used to connect the computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
– Information about the visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We also collect Aggregated Data includes statistical or demographic data, for example we may aggregate your usage data to calculate the percentage of users using a specific Website feature. Aggregate data is not considered personal data, however if we combine aggregate date with personal data we then treat it as personal data.
The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
https://rakutenadvertising.com/legal-notices/services-privacy-policy/
https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.
Cookies
For detailed information on the cookies we use and the purposes for which we use them see the Cookies Policy here.
Managing Cookies - Opt out
Most browsers allow you to disable / refuse to accept cookies. The way to do this will vary by browser and browser version. The links below contain information on the most up-to-date instructions on blocking or deleting cookies.
Please keep in mind, blocking all cookies can have a negative effect on the usability of the website and may block some features from use.
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
How do we receive personal information about you?
Bamford receives this personal information about you when you contact us directly in store or spa or via email or telephone or visit the Bamford or Bamford Grooming Department websites to request to purchase a Bamford Product or service, to create an account, to make a general enquiry, to book an appointment, to provide us with feedback or to request marketing information.
Bamford also receives personal information regarding customers attending “Bamford” spas operated by third parties to ensure that we can provide continuity of service and transition for you through your customer journey with us and to ensure that such operators are providing customers with the best possible service in line with brand requirements. Each such third party operator will have its own privacy policy also.
How do we use Personal Information about you?
We will only use your personal data when the law allows us to – where we need to perform a contract with you, where necessary for our legitimate interests where those are not override by your interests and rights, for legal compliance and where none of those apply, with your consent.
Bamford uses personal information about you:
– To identify who you are when you contact us.
– To provide you with the Bamford Products or services you have requested (and note we may not be able to perform a contract to provide products or services if you fail to provide certain of the information requested.
– To ensure payment for Bamford Products or services purchased and to prevent or detect fraud to understand what Bamford Products or services you may be interested in to contact you regarding your Bamford Products.
– To provide you with e-receipts, to answer your general enquiries or to administer warranty claims or product safety related communications.
– To contact you regarding your Bamford services to update you regarding your appointments to improve Bamford Products or services and to carry out customer surveys.
– To resolve complaints or issues you may have with a Bamford Product or service.
– To manage our relationship with you to send you marketing information about Bamford products or services or general Bamford news that you may be interested in.
– To invite you to Bamford events you may be interested in.
To improve our customer relationship with you We use the information we collect about you:
– To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes to improve our site to ensure that content is presented in the most effective manner for you and for your computer as part of our efforts to keep our site safe and secure.
– You will receive e-newsletters and other electronic marketing from us only if you have requested this.
How will we contact you?
Bamford and its third party service providers (eg, order fulfilment providers, payment processors, marketing fulfilment agencies and customer service agencies) may contact you by post, telephone, email and/or text message, unless you have told us not to or have registered with the telephone or post preference services.
Who do we provide this personal information to?
Bamford will provide your personal information to:
Our service providers who perform services on our behalf, such as our payment fulfilment provider, delivery providers, marketing fulfilment agencies or IT service providers or professional advisers who provide legal, consultancy, insurance or accounting services; analytics and search engine providers that assist us in the improvement and optimisation of the site the payment facilitators to process payment and to undertake fraud prevention checks.
In the event that you make payment over the phone then we directly input the payment details into our encrypted payment system. These details may be held to secure bookings and to draw payment of any booking fees or cancellation fees in line with our cancellation policy but will not be fully visible to us or otherwise recorded.
Where we store your information
All personal information we have about you in store or through the site is stored on secure servers operated by Bamford or its third party IT service providers. Where you have a personal shopping service with members of our staff they may keep your contact details to hand in their records. We have put or ensure that there are in place appropriate security measures and policies to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where information has been passed to our third party service providers it will be stored on their secure servers. These third party service providers have access to your personal information needed to perform their functions, but may not use it for other purposes. Bamford ensures that these third party service providers will only process your personal data in accordance with this policy and applicable Data Protection legislation.
Data Transfers
Your personal information may be processed by Bamford’s third party service providers operating outside the EEA in accordance with this privacy policy. Bamford will use appropriate safeguards to ensure that your personal data is treated securely and in accordance the Data Protection legislation in connection to such transfers or processing of your personal data outside the EEA.
Data Retention
Your personal information will be held in Bamford’s customer relationship management systems for an indefinite period. Bamford will carry out periodic data cleanses of this information to ensure that it is up to date and accurate and it is still reasonably necessary for us to retain it to fulfil the purposes we collected it for.
Your rights
You have the following rights in connection with your personal information processed by Bamford:
Access – you can request access to your personal information and further details about how your personal information is handled by Bamford.
Object – you have the right to object to our processing of your personal information for direct marketing purposes or where the processing isn’t necessary for the purposes of the contract between us or legitimate interests pursued by Bamford or by a third party.
Rectification – you can request rectification of any incorrect personal data held about you.
Erasure – you can request erasure of any personal data where the processing isn’t necessary for the purposes of the contract between us or the legitimate interests pursued by Bamford or by a third party.
You have a right at any time to withdraw consent to receiving marketing from Bamford and/or to amend the delivery method we use. To manage your rights and delivery preferences please follow the instructions in our marketing communications, enquiry forms or write to us at:
Post: Company number 4950534, Bamford Limited, 19 Mossop Street, London, SW3 2LY
Email: info@bamford.co.uk
Where you opt out of marketing, we may nonetheless retain your information in connection with previous transactions or correspondence for so long as is reasonably necessary in connection with the same.
You can also exercise any of these rights at any time by contacting us using the contact details provided below.
Please note when you seek to enforce any of your rights, we may need to request specific information from you to help us confirm your identity as a security measure. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you are concerned or have questions about how Bamford handles your personal data please contact us and we will do our best to assist you.
Please note that you have the right to lodge a complaint with the UK Information Commissioner’s Office (or any other appropriate supervisory authority), which may be accessed through the following link here
Changes to our privacy policy
Bamford reserve the right to revise this privacy policy or any part of it from time to time. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy should be addressed to Bamford Post: Company number 4950534, Bamford Limited, 19 Mossop Street, London, SW3 2LY
Email: info@bamford.co.uk