D R A F T C O P Y F O R M A Y 2 5 t h
GDPR: DATA PRIVACY NOTICE FOR CLIENTS & SUPPLIERS
Ludshott Computing Services (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Ludshott Computing Services is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Ludshott Computing Services, Waggoners, Alma Road, GU35 8JR. For all data matters contact Mr M Simmons, Ludshott Computing Services, Waggoners, Alma Road, GU35 8JR or by using the contact page of this website.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
To inform individuals of news, events or activities.
You may give us information about you by filling in forms on our website, www.ludshottcomputing.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you enquire about our services and products and when you report a problem with our site.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data such as names, email address, phone number and address information. We may obtain your personal data directly from you or a representative of your organisation.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract – In this context, a contract does not have to be a formal signed document, or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this means that the terms have been offered and accepted, you both intend them to be legally binding, and there is an element of exchange (usually an exchange of goods or services for money, but this can be anything of value).
Processing necessary for compliance with a legal obligation – If ordered by authorised bodied such as the police, home office, UK customs & revenue
Consent of the data subject – For marketing and quality feedback we will request explicit permission to contact you via our consent Opt In form (TODO add link)
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with …..
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary in order to correspond with you on work that you have commissioned us to carry out. This will include retaining your company name and company email address for at least 4 years after the initial work as legal cases can follow on. When visiting our website you browser’s IP address records will be deleted each year ?.
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract with your company.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
[The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA];
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not transfer personal data outside the UK
11. Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Mark Simmons via the contact page of this website.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.