BACKGROUND:
Above The Line Set Assistance and Security Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our subcontractors and employees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Above The Line Set Assistance and Security Ltd.
A Limited Company registered in England under company number 7060683.
Registered address: Gilmoora House, 57-61 Mortimer Street, London W1W 8HS
Trading Address: Pinewood Studios, Iver Heath, Bucks SL0 0NH
Data Protection Officer: Daniel O’Toole.
Email address: Daniel@abovethelinesecurity.com.
Telephone number: 02031376160
Postal Address: As Trading Address Above
We are registered with the ICO and our registration number is: ZA010952
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 10 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way
i) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us
• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• SIA Licence number
Your personal data is obtained from the following third parties:
• Experian Credit Searches;
• Referees you supply us.
• How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
• Your personal details are required in order for us to enter into a contract with you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email, text, phone, or post that you have opted-in to (you may unsubscribe or opt-out at any time by letting us know so we can remove you from our contact lists. You can let us know if person or by email, phone, letter or text).
6. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• Data supplied to us will be kept only while you work with us and for the statutory period we are required to retain records by HMRC;
7. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK in normal day to day business. This means that it will be fully protected under the GDPR.
AND
On occasions where we have to provide details of subcontractors to a third party to fulfil a contract we will only release the information needed to complete the contract. An example of this could be providing a list of subcontractors who are providing services to a US Based company. The majority of our clients are UK based and even when the parent company is USA based they may be using a UK based subsidiary. Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 10 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
• Encrypted transfer, collection and storage or data using the most up to date technology available to us.
• Screening of individuals that handle data
• Only collecting and processing the exact data we use and keeping it safely stored while we need it.
8. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to two important exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for contracting purposes. This includes subsidiaries and our holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply products services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
• HSBC Banking Group for Payment Processing.
• Email Signature Rescue Pty
• Signable for Electronic Signature of Documents
• SMS bulk text messaging for delivery of text messages
• Professional services such as our Accountant for Processing Accounts
• Google G Suite for Business
Most of these third parties will have freely available privacy policies if you want to research them yourself, but we can supply any information you need.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
9. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
10. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Daniel O’Toole:
Email address: daniel@abovethelinesecurity.com.
Telephone number: 02031376160.
Postal Address: Pinewood Studios, Iver Heath, Bucks SL0 0NH.
11. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website and sent to you by email.
Dated: 23 May 2018