Our Co Data Privacy Notice

The Real Wrap Co holds/collects personal data on its employees/customers/suppliers. This data privacy notice details the personal data The Real wrap may retain, process and share with third parties relating to your business and employees.


The Real Wrap Co is committed to ensuring that your information is secure, accurate and relevant.


To prevent unauthorised access or disclosure, we have implemented suitable physical, electronic, and managerial procedures to safeguard and secure the personal data we hold.


We respect the rights of individuals and are committed to handling personal information responsibly and in accordance with the applicable law.


This notice sets out the personal information that we collect and process as a data processor, the purpose of the processing and the rights connected with it.

The following are The Real Wrap’s key third-party processors in relation to client data

• RJL – Sales and order processing software
• Citation – Online Platform for the purpose of storing employee employment information
• Sage Accounts – Accounting software
• Sage Payroll – Payroll software
• Mail Chimp – Marketing Platform used for the purpose of distributing group emails
• Drop Box – Storage of artwork
• Indeed – Online recruitment platform

The Real Wrap Co may collect and process data about you including the following:

Data which can identify you
Contact details
Names, Date of Birth. Gender

Telephone numbers, email  addresses,    

IP addresses, emergency contact   information, business    information

Employment details
Financial Information
Sensitive personal data
Website Information
Job Titles, Salary, Employment dates
Bank Details

Data which will Identify your religious, political, racial or ethnic origin

Information provided at the time of subscribing to our services or entering of competitions, report issues with our website, cookies which will distinguish you from other users


Data will only be used for the purposes indicated when you submit the data or as detailed under this privacy policy.


We will normally on collect personal information from you when we have your

consent to do so.


We will use the personal information held about you in the following ways:

• Update and enhance our records

• Compile information relating to your use of our products and make recommendation about products or services that may interest you

• To carry out our obligations arising from any contracts entered into between you and us to provide you with information, products and services that you request from us


• Inviting you to participate in research studies/or market research


• We may analyse your data to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information


• To ensure that we are able to send information relating to the service we provide you such as change in office hours, new products, menu changes, details of any product recalls and updates to any allergen information


We will not transfer any of your data to any third parties with your permission or unless indicated in this privacy policy.


We may disclose your personal information to third parties without obtaining further consent from you including:

• Where we outsource any of our business functions under which we collect or store your data, in which case we will ensure that any such service provider adheres to at the same obligations of security with regard to your data as undertaken by us


• Where we have a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and any other agreements.


• We may also disclose or share your personal data in order to protect our rights, property, or safety of our employees, customers or others. This will include exchanging information with other companies or organisations for the purpose of fraud protection

Your personal data will never be sold to third parties for the purpose of marketing.


To ensure that the security of your data at all time we have policies and controls in place.


Most of the information we hold on your will be used and stored in the UK, however, we use Third Party providers that are not based in the UK. We will make sure that any transfer to another country is legal and that your information is always kept safe.


We may use personal information where we consider it necessary for complying with laws and regulations, including collecting, disclosing personal information as required by law (e.g for tax, health and safety, anti discrimination laws), under judicial authorisation, or to exercise or defend the legal rights of The Real Wrap Co.


We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently. We may also collect and process personal where it is necessary for The Real Wrap Co’s legitimate interest, for example processing customer feedback.


Personal information will be stored in accordance with applicable laws and kept for as long as needed to carry out the purpose as described in this Notice or as otherwise required by applicable law. Generally, this means your personal information will be retained until the termination of employment, or relationship with The Real Wrap plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g judicial or disciplinary actions) or to document the proper termination of employment or work relationships (e.g. to tax authorities)


You have the right to ask us not to process your personal data for the purpose of marketing. We will usually inform you (prior to collecting your data) if we wish to use your data for such purposes or if we wish to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will gain your consent to these activities.


The Act gives you the rights to access information held about as detailed below:

1. Access, correct, update or request deletion of personal information


2. Object to processing of personal information, ask us to restrict processing of personal information or request portability of personal information


3. If we have collected and processed personal information using a person’s consent, then this can be withdrawn at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to withdrawing, nor will affect processing of personal information conducted in reliance on lawful processing grounds other than consent


4. You have the right to complain to a data protection authority about our collection and use of personal information. For more information, please contact your local data protection authority. In the United Kingdom, the data protection authority is the information commissioner’s officer.

You can read more about these rights at

Please address any questions or requests relating to this Notice to The Real Wrap Co Data Protection Officer Gemma Dare, HR Manager - Gemma.D@realwrap.co.uk

Unless you have told us not to, we will send our customers marketing information relating to products and services that we think maybe of interest and relevant to them. You can opt-out of receiving these communications at any time by using the unsubscribe option on our emails.


This policy will be subject to periodic review and it is recommended that you review this document from time to time to ensure that you are aware of any amendments applicable to the retention, processing and sharing of personal data.

Our Food Safety & Quality Policy

Real Wrap Co are committed to producing high quality, safe, legal and wholesome products in accordance with the requirements of all relevant UK and EC food legislation, customer codes of practice and industrial regulations. This ensures the expected quality standards of our customers, are met and their expectations are exceeded.   


As a company, Real Wrap Co are continually monitoring and reviewing operating procedures to ensure customers’ expectations and statutory requirements are being adhered to. To achieve this, the company are committed to maintaining and improving standards to food safety, quality, and hygiene through the principles of Hazard Analysis and Critical Control Points (HACCP), with a fully implemented Good Manufacturing Practices (GMP) as set out within the site Food Safety and Quality Manual (FSQM), as well as Traceability and Crisis Management.


Real Wrap Co are committed to the annual accreditation to the SALSA (Safe and Local Supplier Approval) standard, STS and the Local Authority.  


Real Wrap Co are committed to achieving its objectives by adopting a policy of employing sufficient staff, training staff and developing and encouraging those staff. This is achieved by providing adequate and appropriate tools and resources to fulfil tasks and to provide information and feedback through an open communication structure at all levels throughout the organisation.


Real Wrap Co also ensures the traceability of all products produced.


Real Wrap Co seeks to become the preferred supplier to our customers through sustained improvement of quality on all aspects of our business, such that our quality becomes a competitive advantage.

The management of this policy is undertaken by the Technical Manager of the company with the support of the management team and all company personnel.  The team review procedures, taking into account business benchmarking, latest industry standards, legislation and customer feedback.

Our aim is to consistently manage and deliver our products to meet the needs and expectations of our customers.

Chilled production area which is maintained at a constant 0-8oC,low risk preparation room, separate chilled storage areas for incoming and outgoing goods, an excellent distribution network using our own fleet of refrigerated vehicles, onsite training facilities.

The local environmental health.

Real Wrap Co-operates its own fleet of refrigerated vans which  deliver daily into Bristol, Wales and the South West.  All our vehicles are temperature controlled with built in temperature monitoring and tracking system and 3rd Party Companies trusted.   

Unit 2 Haslemere Industrial Estate, Avonmouth, BS11 9TP

Unit 13 St. Andrews Trading Estate, Avonmouth, BS11 9TP

Modern Slavery & Human Trafficking Policy

The purpose of this policy is to address the issue of modern slavery and human trafficking.

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

The Real Wrap has a zero-tolerance approach to modern slavery and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, agents, contractors, suppliers or any other people or bodies associated with the business.

All the management team have overall responsibility for ensuring this policy complies with our legal obligations, and that all those under our control comply with it.

The effectiveness of this policy will be monitored and reviewed by the HR Department to ensure the Company’s continuing compliance with relevant legislation, to meet business requirements, and to identify areas in need of improvement.

The HR Department has primary and day-to-day responsibility in relation to those directly employed by us for implementing this policy and monitoring its use and effectiveness and dealing with any queries about it.

All persons working for The Real Wrap must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. All persons working for The Real Wrap are required to avoid any activity that might lead to, or suggest, a breach of this policy.

All persons working for The Real Wrap are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier at the earliest possible stage.

This policy forms part of the HR policies and is available on request.

All employees are required to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce our approach as appropriate thereafter.

In order to give effect to our zero-tolerance approach, we are developing systems to ensure that those in our supply chain and those who work for us implement our policy and we do already have some implemented systems in place together with the Group’s business practices.

Any breach of this policy will generally be treated as gross misconduct and may result in dismissal without notice.

We may terminate our relationship with individuals and organisations working on our behalf if they do not comply with this policy.

internal policy on Coronavirus (COVID-19)

This policy details measures that must be taken due to changes and threats presented by the current COVID-19 pandemic. A full risk assessment has been conducted, is available for ­­­­all staff on request. The risk assessment and this policy shall be updated weekly minimum, or earlier should any relevant government and/or scientific guidance prompt any changes to our situation and necessary controls to ensure the safety of our staff and products.


Staff should work from home were feasible. Where not feasible, staff on site must adhere to the following measures, in addition to existing personal hygiene requirements, as defined by the Risk Assessment.

Social distancing of at least 2m between persons must be obeyed whenever possible. Breaks and work patterns should be adjusted where feasible to support this. Hands must be washed frequently and sanitised using the hand dispensers located around both units, particularly after touching common surfaces such as door handles. Common surfaces should be wiped down with sanitiser throughout the day. Equipment i.e. computer keyboards should not be shared between staff and should be cleaned or wiped down daily.

Where appropriate distancing is not feasible and staff must work face to face for prolonged periods i.e. on some workstations in the High Care facility, these staff will be at a higher risk of infection and therefore will be required to wear a visor whilst working in close proximity to others. Visors will be available for all other members of staff on an optional basis. Appropriate use, hygiene and storage of visors is detailed in the procedure Use of Face Visors for Infectious Disease Control (SOP0099), with records kept on the Visor Control Sheet (PCS0099).

Non-essential visitors and contractors are discouraged from entering the site, and remote meetings should be conducted where feasible. Where this is not possible, the visitor/contractor should complete the COVID-19 Visitor and Contractor Questionnaire in addition to the Visitor/Contractor Regulations and Questionnaire (PCS005) prior to entering the site. It is the responsibility of the host to ensure that the interviewee reads, understands and completes the above-mentioned questionnaires, and adheres to the measures whilst in site.

Any staff having been in contact with anyone showing the following symptoms in the previous 14 days should not come into work and should notify their manager. If any staff are already on site and either begin to experience symptoms, or learn that others they have been in contact with in the previous 14 days have reason to believe they may be infected, the staff member should leave the site immediately and notify management.

Cough  /  Fever  /  Vomiting  / Difficulty breathing  /  Tiredness  /  Diarrhoea  /  Headache  /  Loss of taste or smell  /  Chest pain  /  Skin rash  /  Sore throat  /  Aches and pains

Staff with reason to believe that they, or someone in their household, are potentially infected should call 111.

Interviews and meetings should be conducted remotely where feasibly. Where this is not possible, the interviewee should complete the COVID-19 Visitor and Contractor Questionnaire in addition to the Visitor/Contractor Regulations and Questionnaire (PCS005) prior to entering the site. It is the responsibility of the host to ensure that the interviewee reads, understands and completes the above-mentioned questionnaires, and adheres to the measures whilst in site. Taking interviewees into areas where social distancing is not feasible i.e. High Care production room is discouraged and requires authorisation of a Director or the Technical Manager.

Any staff returning to the site after being away due to furlough, holiday, sickness or any other reason must read the current policy and complete the Return to work and new staff questionnaire in addition to the Return to work questionnaire (PCS0093). The questionnaire must be reviewed, and entry authorised by a member of senior management, depending on the information provided in the questionnaire before the returning staff member can enter the site.

Hand sanitisers should be carried in cabins and hands sanitised frequently throughout the day. Avoid making any physical contact with others i.e. shaking hands and ensure social distancing is maintained where possible. Hands should be cleaned or sanitised after leaving each customer site. If facilities at customer sites must be used (i.e. toilet), distancing measures must be followed where possible and hands washed where appropriate including on exiting the facility and before re-entering the vehicle, or use of the hand sanitiser where hand wash taps are not available. The wearing of face masks is encouraged in customer sites where distancing is not feasible.  Agency staff are discouraged, however where essential they must follow the measures set out in this policy and complete the questionnaires as defined within “New staff”.

Any persons arriving in the UK from overseas must isolate accordingly in line with the current Government guidance before entering the company premises.


Real Wrap Co are committed to protection of the environment through the implementation of an effective and sustainable surplus management programme. This programme is reviewed on a regular basis to ensure that it continues to meet or exceed legislative and regulatory requirements & is of benefit to both the company and the community.

In order to successfully manage environmental matters, recycling and surplus; systems and facilities are designed to make it easier for staff to comply, in addition to managing waste where it is created. Real Wrap Co are aware that prevention is better than cure and strive to eliminate causes of waste through process control and application of the ‘food waste hierarchy’ (see end of document).

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, agents, contractors, suppliers or any other people or bodies associated with the business.

Whilst responsibility for environmental impact & waste sits with Directors, all staff at Real Wrap Co are briefed on appropriate waste control, disposal & reduction as part of the induction process.

All the management team have overall responsibility for ensuring this policy complies with our legal obligations, and that all those under our control comply with it. Management is committed to working with the Local Authority and appointed recycling and surplus management contractors to raise awareness of environmental issues amongst the staff, and visitors.

We are the first food-to-go manufacturer in the world to achieve carbon-negative status. We are working closely with specialist emissions advisors to offset our carbon emissions and improve the lives of people in less fortunate countries.

• We have worked with all our suppliers to develop effective and economically viable alternatives to single-use packaging. We have avoided “solutions” which give the perception of being sustainable yet may be worse than the current option.

• Cellulose lined sandwich wedge launched in Autumn 2020. Industrially compostable and 100% recyclable through mixed recycling streams.

• Only using FSC card. Card sourced from responsibly managed forests.

• Switch to RPET for all hard-clear plastic as used in salad pots, snack pots, platters etc. This is made from 95-100% recycled plastic and has been recyclable nationwide since the early 1990’s. Our supplier produces RPET in the UK within a carbon neutral factory powered by hydro and solar electricity.

• Reducing plastic used in packaging by switch to card alternatives where appropriate. Started with our Kraft Salad Bowls in Autumn 2019, switching to plastic-free card platter boxes in Spring 2022.

• Moving towards bio-plastic films for flow-wrapped items in Spring 2022. Working with suppliers to develop effectives films, aiming to achieve maximum shelf-life and maintain hermetic seal over product life, including for hot items.

• Removed adhesive labels from majority of products which can cause issues within recycling streams. Switching to FSC certified card bands, keeping materials separate for easy recycling.

• Researching and supporting the development of on-site composters and their potential use within catering facilities. This would eradicate the need for recycling streams which reach industrial composters.

• We are always looking for ways to educate and engage with customers about are sustainability efforts.

• Encourage greater recycling and provide compelling information about the environmental benefits of behavioural changes through responsible waste disposal

• Our enhanced design and branding service works to produce awareness campaigns through packaging and POS materials.

• We also are looking at initiatives that address and seek to mitigate the uneven provision of recycling facilities around the country and how these affect our customers. Whilst our packaging is widely recyclable that doesn’t mean it is universally possible.

• Switch to biofuels used in our vans.

• All our vehicles run on Euro-6 engines, the most CO2 efficient engine out there.

• Trialling Electric vehicles on our local routes.

• All our delivery routes are mapped daily to ensure they are going the most efficient route to avoid doubling back on ourselves. Where appropriate we backhaul ingredients from suppliers

• All drivers are trained in house on safe and effective driving techniques, part of this covers economical driving. The in-van trackers monitor and detect harsh breaking and accelerating, drivers are investigated should this be out of the ordinary.

• We record van fuel consumption daily, there are targets set based on the route they take, and drivers are incentivised to hit their targets

• For our deliveries we use plastic reusable bread trays. They are designed to fit an optimum number of sandwiches in (average 50).

• Adding more plant-based options to our menu with every update.

• 25% of our menu is plantbased (including drinks/snacks).

• Partnership with Oumph! to create a range designed for the ‘flexitarian’ market, encouraging a reduction in meat consumption with great tasting alternatives.

• All factory food-waste sent to anaerobic digestion chambers. Here it is turned into electricity, gas and fertiliser to power our local city of Bristol.

• Partnered with local charity Fare Share South-West to ensure our product overruns do not go to waste. They are distributed across Bristol to help feel the vulnerable.

• Working with local brewery to turn our waste bread crusts into beer.

• Careful operational planning to avoid ingredient over-ordering and unnecessary food-waste.

This policy forms part of the HR policies and is available on request.

It is intended that there will be continued improvement in this area. Progress will be regularly reviewed and discussed at the Management review meetings.