1.2 This Privacy Standard applies to all Personal Data we process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.
2.1 We recognise that the correct and lawful treatment of Personal Data will maintain confidence in our business and will provide for successful operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.
3. PERSONAL DATA PROTECTION PRINCIPLES
3.1 We adhere to the principles relating to processing of Personal Data set out in the law which require Personal Data to be:
(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
(d) Accurate and where necessary kept up to date (Accuracy).
(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
(h) Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).
We are responsible for compliance with the data protection principles listed above (Accountability).
4. HOW WE USE YOUR DATA
4.1 We will ensure that personal data is processed lawfully, fairly and in a transparent manner in relation to the Data Subject. We will only collect, process and share Personal Data fairly and lawfully and for specified purposes. The law restricts our actions regarding Personal Data to specified lawful purposes.
The law allows processing for specific purposes, some of which are set out below:
(a) the Data Subject has given their Consent;
(b) the processing is necessary for the performance of a contract;
(c) to meet our legal compliance obligations;
(d) to protect the Data Subject’s vital interests;
(e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects.
4.2 A Controller must only process Personal Data on the basis of one or more of the lawful bases set out above. This includes Consent. A Data Subject consents to processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Data Subjects must be easily able to withdraw Consent to processing at any time and withdrawal must be promptly honoured.
4.3 The law requires us to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Given the nature of our business, we rarely collect Personal Data directly from Data Subjects. If we do, we will provide the Data Subject with all the information required by the law including how and why we will use, process, disclose, protect and retain that Personal Data by providing a copy of this policy.
4.4 Personal Data must be collected only for specified, explicit and legitimate purposes. We will not use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained.
4.5 Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. We will rarely collect Personal Data but in the event that we do, we will only collect what we need to carry out our services.
4.6 Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. We will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. Our customers are responsible for checking the accuracy of any Personal Data we access in carrying out our services.
4.7 Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. We will ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time.
4.8 Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). You are responsible for protecting the Personal Data you hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data.
5. REPORTING A BREACH
The law requires us to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject. If we know or suspect that a Personal Data Breach has occurred, we will immediately contact your person or team designated as the key point of contact for Personal Data Breaches. We will preserve all evidence relating to the potential Personal Data Breach.
6. TRANSFERRING DATA
The law restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the law is not undermined. You may only transfer Personal Data outside the EEA if one of the following conditions applies:
(a) the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects’ rights and freedoms;
(b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
(c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
(d) the transfer is necessary for one of the other reasons set out in the law including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.
7. HOW YOU CAN CONTROL YOUR DATA
Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
(a) withdraw Consent to processing at any time;
(b) receive certain information about our processing activities;
(c) request access to their Personal Data that we hold;
(d) prevent our use of their Personal Data for direct marketing purposes;
(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
(f) restrict processing in specific circumstances;
(g) challenge processing which has been justified on the basis of our legitimate interests or in the public interest;
(h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;
(i) object to decisions based solely on Automated Processing, including profiling (ADM);
(j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
(k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
(l) make a complaint to the supervisory authority; and
(m) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.
We will verify the identity of an individual requesting data under any of the rights listed above.
We implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. We will continue to train our staff, review policies and procedures and carry out periodic reviews and audits to assess compliance.
9. RECORD KEEPING
The law requires us to keep full and accurate records of all our data processing activities. In the majority of cases, we will access external systems for the implementation of our service. In each case, we may access personal data that our customers control. We will keep appropriate records for these purposes and for the processing of our internal personal data.
10. TRAINING AND AUDIT
We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.
11. PRIVACY BY DESIGN
11.1 We are required to implement Privacy by Design measures when processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.
11.2 We will assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process Personal Data by taking into account the state of the art, the cost of implementation, the nature, scope, context and purposes of Processing and the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.
12. AUTOMATED PROCESSING AND DECISION-MAKING
12.1 Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:
(a) a Data Subject has Explicitly Consented;
(b) the Processing is authorised by law; or
(c) the Processing is necessary for the performance of or entering into a contract.
12.2 If we intend to carry out Automated Processing (including profiling), then this right will be explicitly brought to the Data Subject’s attention and presented clearly and separately from other information.
13. DIRECT MARKETING
We are subject to certain rules and privacy laws when marketing to our customers. For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.
14. SHARING PERSONAL DATA
Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. We may only share the Personal Data we hold with third parties, such as our service providers if:
(a) they have a need to know the information for the purposes of providing the contracted services;
(b) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
(c) the transfer complies with any applicable cross border transfer restrictions; and
(d) a fully executed written contract that contains law approved third party clauses has been obtained.
CHANGES TO THIS PRIVACY STANDARD
We keep this Privacy Standard under regular review. This version was last updated in June 2018.
Information we collect from you
We gather information that relates to, and can identify you (e.g. your name and email address) and information that does not identify you (e.g. a visitor’s behaviour patterns when they visit our website).
We collect information when you send us an enquiry through this website.
How we gather information
Information is gathered in two ways:
- indirectly (e.g. using this website)
- directly (e.g. when you buy our products)
Use of your information
We may use your personal information to:
- remember you when you visit our website by using cookies.
- contact you by email, mail or telephone to discuss your enquiry, if you have provided us with these details
- ensure materials on the website are presented in the most effective manner for you and your computer
- collate and log numeric internet addresses to improve the website and to monitor website usage
If you have not purchased our products, engaged with us at any of our events or shown any activity on our website for more than one year, we will remove your information from any database to ensure we are only keeping data we need.
If at any point, you would like us to remove any information we hold that relates to you, please contact us at email@example.com