We have appointed a Data Protection Officer who approves any changes to this policy.
What data do we collect?
Personal data is any information that relates to an identified or identifiable individual.
We collect information about existing and potential customers to improve the services we offer and to enter and fulfil commercial arrangements.
We aim to keep personal data collection and storage to a minimum. We collect and use the following personal (and non-personal) data:
- Contact name
- Company name
- Landline phone number
- Mobile phone number
- Email address
How do we use your data?
We will use personal data as necessary in order to:
- Personalise content, business information or user experience
- Make contact to discuss the services we provide
- Create and manage customer accounts
- Meet any legal and regulatory obligations
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
We may, with your prior written consent pass your data on to third parties who provide services to us where this is required to fulfil our contract with you.When we do this, it is only shared with organisations we have data sharing agreements in place with and with the knowledge that they care for your data as carefully as we do, keep it confidential and use it only for the agreed purposes above.
We will only retain personal data you provide until you ask us to delete it or for as long as is necessary to allow us to meet our contractual requirements with you.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of any terms and conditions you agreed to or otherwise where required by law. We will co-operate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders. We shall not be obliged to give you any further notice of this.
Throughout your relationship with us, we will hold your personal data securely in our systems. This will include any data provided by you or others in various ways, including (but not limited to) in applications, emails and letters, during telephone calls and conversations in our offices, when registering for services, and when using our website.
We will not carry out further processing of personal data or pass personal data to third parties other than that necessary to fulfil our contractual obligations to you or our customer.
Under Data Protection regulations individuals have a number of rights. These are as follows:
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data.
Right of access
Individuals have the right to access their personal data and supplementary information. Individuals have the right to obtain:
- confirmation that their data is being processed
- access to their personal data
- other supplementary information
We will not charge for initial requests to provide information, but may charge a fee if requests for further copies of the same information are made. We will provide the requested information to you within a month of receiving your request, unless the request is complex or numerous in which case, we may extend this period by up to a further two months.
Where a request is manifestly unfounded or excessive, particularly if it is repetitive, we may charge a fee to provide the information requested or refuse to respond. In these instances, we will inform you and explain our reason.
Before we proceed with any request, we will take steps to verify the identity of the person making the request.
Right to rectification
Individuals have the right to request that inaccurate personal data is rectified or completed if it is incomplete. If you make such a request, we will take steps to verify whether the data is accurate. Where we accept that the information is inaccurate, we will take steps to rectify it immediately. If we believe that the information is accurate and does not require rectification, we will notify you and explain our reason.
Where a request is manifestly unfounded or excessive, particularly if it is repetitive, we may charge a fee to rectify the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.
Right to erasure (known as the “Right to be forgotten”)
Individuals have the right to have their personal data erased if:
- the personal data is no longer necessary for the purpose which it was originally collected
- we rely upon consent as our lawful basis for holding the data and you withdraw that consent
- we have processed your personal data unlawfully
- we have to do it to comply with a legal obligation
The right to erasure does not apply where processing is necessary for one of the following reasons:
- to exercise the right of freedom of expression and information
- to comply with a legal obligation
- for the performance of a task carried out in the public interest or in the exercise of official authority
- for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing
- for the establishment, exercise or defence of legal claims
Where a request is manifestly unfounded or excessive, particularly if it is repetitive, we may charge a fee to remove the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.
Right to restrict processing
Individuals have the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data in the following circumstances:
- you contest the accuracy of your personal data and we are verifying its accuracy
- the data has been unlawfully processed and you oppose erasure, requesting restrictions instead
- we no longer need the personal data, but you need us to keep it in order to establish, exercise or defend a legal claim
- you have objected to us processing your data and we are considering whether our legitimate grounds override your request
If you choose to exercise this right, we may not be able to proceed with a transaction or provide you with our advice. This may mean that we are unable to submit or progress a transaction with a product provider. In these instances we will notify you of the impact of your request.
Right to data portability
The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. The right to data portability only applies:
- to personal data you have provided to us
- where the processing is based on your consent or for the performance of a contract
- where processing is carried out by automated means
- When responding to such a request, we would provide the personal data in a structured, commonly used and machine-readable form, typically a .CSV file. We will provide this to you within one month of receiving your request. If your request is complex or requires more time, we may extend this period by up to a further two months. We will contact you and inform you why it will take longer.
Right to object
Individuals have the right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
- direct marketing (including profiling)
- processing for purposes of scientific/historical research and statistics.
If you exercise your right to object, we will stop processing your personal data unless:
- there are compelling legitimate grounds for us to continue to process, which override your interests, rights and freedoms
- the processing is for the establishment, exercise or defence of legal claims
You can exercise your right to object at the first point of contact with us or at any other time by contacting us a detailed below. If exercising your right to object affects or prevent us from being able to provide you with one or any of the services we offer we will inform you.
To exercise any of your rights detailed above you can contact us as detailed below:
We take the security and confidentiality of information very seriously. If you ever feel you need to complain about how we’ve handled your information and data you can contact us as via email on [email protected] or by telephone on +44 (0) 1793 792 200.
If you’re still unhappy with any aspect of how we handle your personal information, you also have the right to contact the Information Commissioner’s Office (ICO). The ICO is the UK’s independent body set up to uphold information rights.
Via its website: https://ico.org.uk
Or in writing to
Information Commissioner’s Office
Call: 0303 123 1113
Should you object to any alteration, please contact us.