The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of [Carlton Cleaning Contractors Ltd]. Furthermore the way it processes, stores and protects user data and information will also be detailed within this policy.
When we collect and use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as a ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
Key terms of the policy:
|We, us, our||[Carlton Cleaning Contractors Ltd]|
|Personal data||Any information relating to an individual|
|Special category personal data
Genetic and biometric data
|Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.
Data concerning health, sex life or sexual orientation.
Personal data we collect about you
The section below sets out the personal data we may collect when taking your initial enquiry to see how we may assist you.
|Personal data we will collect|
This personal data is required to enable us to provide our service to you. If you do not provide personal data when we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you. However, we may also collect information:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g.:
- AML checking software;
- credit reference agencies;
- client due diligence providers;
- from a third party with your consent, e.g.:
- your bank or building society, another financial institution or advisor;
- consultants and other professionals we may engage in relation to your matter;
- your employer and/or trade union, professional body or pension administrators;
- via our information technology (IT) systems, e.g.:
- CRM, document management and time recording systems;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The following information explains what we use (process) your personal data for and our reasons for doing so:
- To deal with your enquiry and to direct you to the relevant person
- Conducting checks to identify our clients and verify their identity
- Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. AML checks
- Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
- Ensuring business policies are adhered to, e.g. policies covering security and internet use
- Operational reasons, such as improving efficiency, training and quality control
- Ensuring the confidentiality of commercially sensitive information
- Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures
- Preventing unauthorised access and modifications to systems
- Updating and enhancing client records
- Statutory returns
- Ensuring safe working practices, staff administration and assessments
Our reasons for using your data:
- To take steps at your request before entering into a contract
- To comply with our legal and regulatory obligations
- For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
The above does not apply to special category personal data, which we will only process with your explicit consent.
Who we share your personal data with
We routinely share personal data with:
- our insurers and brokers;
- our bank and finance providers;
- external service suppliers, representatives and agents that we use to make our business more efficient, e.g. typing services, marketing agencies, document collation or analysis suppliers;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
How long your personal data will be kept
We will keep your personal data after we have taken your initial enquiry. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law; and
- you have signed up to any of our newsletters (until you unsubscribe)
- to prolong your entitlement to freely use our intellectual property under licence from us as described in our terms and conditions of business
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data. Further details on this are available on request. When it is no longer necessary to retain your personal data, we will delete or anonymise it.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
|Not to be subject
to automated individual decision-making
|The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and client reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
We may use your personal data to send you updates (by email, text message, telephone or post) about marketing and sales developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us by telephoning 01752 204119 or emailing firstname.lastname@example.org
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information, so in the first instance we ask you to contact us with any questions or complaints.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
How to contact us
Carlton Cleaning Contractors Ltd / Unit 2 Riverside Business Park, New Passage Hill, Plymouth, PL1 4SN / 01752 204119 – email@example.com