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DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS



Introduction

Complete Networks Ltd are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the "GDPR").

1. Definitions

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?

Complete Networks Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Complete Networks Ltd, The Millhouse, Station Road, Castle Donington, DE74 2NJ. Tel: 01332 497 990. For all data matters contact OUR DATA REPRESENTATIVE Justin Clarke on 01332 497 990.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

Legal obligations, Contract, Consent, Vital Interests, Public Task, Legitimate Interests.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we may process the following categories of your data however most of the data that we process is limited to Name, job title and telephone.

Details of the type of information that we may hold, depending on the requirement to do so is listed but not limited to the list below.

  • Personal data: Name, Title, Job Title, DOB, Address, Tel, Email, ,bank details, NI, C.V, birth certificate, passports, photo ID, vehicle information, Connection and usage history, Passwords, Asset list, Contract, Invoices, purchase orders, Call logs, Fax number, Qualifications.
  • Special categories of data: Health, Medical information.

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:

In accordance with data protection law, we are obliged to inform you that we are using your information as described in this policy on one or more of the following legal bases:

  • you have given your consent to us using your information as described in this notice;
  • the use is necessary to perform a contract between us or to take steps which you requested us to take before entering into a contract;
  • the use is necessary to comply with a legal obligation to which we are subject;
  • the use is necessary to save your life or that of another individual;
  • the use is necessary for the performance of a task carried out in the public interest or in the exercise of our official authority;
  • the use is necessary for the purposes of our legitimate interests, including direct marketing, fraud prevention or preventing crime and protecting public security.

b) Special categories of personal data (article 9 of GDPR)

USE OF YOUR SENSITIVE PERSONAL INFORMATION

We may on occasion collect sensitive personal information about you. By way of example, information about your racial or ethnic origin may be included within the identification information you provide to us as part of our account opening process and/or we may check and record your identification information during our verification process on collection of our hire equipment.

We will use this sensitive personal information for the purposes of identifying individuals to combat fraud and other criminal activity.  We will share this sensitive personal information with the police and our insurers and other organisations that provide similar products and services to ours for the purpose of fraud and crime prevention.

More information on lawful processing can be found on the ICO website.

6. Sharing your personal data

We cannot run our business or provide many of our services and benefits without involving other people and businesses and sometimes we pass your information to these other people and businesses as set out below.  We only share your information where we can do so in accordance with our legal data protection and privacy obligations.  We share the information we collect with:

  • Our different business units that have relationships with our customers and users. We do so because we hope to have a relationship with you across our different business units and we want to be able to provide you with the same value and high quality of experience.
  • Other people and businesses who help us provide our Site and related services to you, for example, information technology companies who host and/or maintain our Site and payment services companies who enable you to use payment cards with us.
  • Analytics and search engine providers who assist us in the improvement and optimisation of our Site.
  • Our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
  • Credit reference agencies who provide anti-fraud and credit score information to us, central and local government departments, for example the Driver Vehicle Licensing Agency (DVLA) and local authorities who run the UK electoral rolls, banks and finance companies who also provide anti-fraud services and customer insight companies (as set out above), in each case as necessary in order to benefit from their services. Where we do so for anti-fraud purposes, the recipient organisation may hold your information on file for the purpose of their fraud prevention services in future. We may also share your information, including late payment information, with credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors. 
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • The prospective buyer of any part of our business or assets that we may sell.
  • Our professional advisers for example our lawyers, accountants and technology consultants when they need it to provide advice to us.
  • Our registrars in relation to the administration of our shareholdings, including updating the share registers and managing dividend payments.
  • The police, local authorities, HM Revenue & Customs (HMRC), the courts and any other central or local government bodies where they request it and/or where we may lawfully disclose it, for example for the prevention and detection of crime.
  • Other people who make a subject access request to us, where we are allowed to do so by law (see Managing Your Information below for what we mean by a subject access request).

We may also share the information we collect where we are legally able to do so, for example, to comply with a court order.

7. How long do we keep your personal data?

In accordance with our legal data protection and privacy obligations, we will only retain your information for as long as is necessary for the purpose for which it was collected. We will then either securely delete it or anonymise it so that it cannot be linked back to you.

8. Providing us with your personal data

We require your personal data as it is a contractual requirement or a requirement necessary to enter into a contract in order to conduct and honour our business arrangements.

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 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 EEA.

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.

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our [DATA PROTECTION OFFICER/OUR DATA REPRESENTATIVE] on [insert contact details].

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 or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.




DATA RETENTION POLICY WITH SCHEDULE



This is the Data Retention Policy of Complete Networks Ltd


Introduction

We recognise that in the running of our business, we collect and process personal data from a variety of sources. This personal information is collated in several different formats including letters, emails, legal documents, employment records, operations records, images and statements. The personal data is held in both hard copy and electronic form.


Aims of the policy

Our business will ensure that personal data that we hold is kept secure and that it is held for no longer than is necessary for the purposes for which it is being processed. In addition, we will retain the minimum amount of information to fulfil our statutory obligations and the provision of goods or/and services - as required by the data protection legislation, including the General Data Protection Regulation (GDPR).

Retention

This retention policy (with its schedule), is a tool used to assist us in making decisions on whether a particular document should be retained or disposed of. In addition, it takes account of the context within which the personal data is being processed and our business practices.

Decisions around retention and disposal should be taken in accordance with this policy.

Where a retention period of a specific document has expired, a review should always be carried out prior to the disposal of the document. This does not have to be time-consuming or complex. If a decision is reached to dispose of a document, careful consideration should be given to the method of disposal.


Responsibility

Tim Hughes is responsible to keep this retention schedule up to date, to reflect changing business needs, new legislation, changing perceptions of risk management and new priorities for our business.

Tim Hughes is responsible for determining (in accordance with this Policy) whether to retain or dispose of specific documents.

Tim Hughes may delegate the operational aspect of this function to Emma Bullivant.

Emma Bullivant should inform Tim Hughes if in any doubt about minimum retention periods or if the retention of a document is necessary for a potential claim.


Disposal

We must ensure that personal data is securely disposed of when it’s no longer needed. This will reduce the risk that it will become inaccurate, out of date or irrelevant.

The method of disposal should be appropriate to the nature and sensitivity of the documents concerned and includes:

  • Non-Confidential records: place in waste paper bin for disposal
  • Confidential records: shred documents
  • Deletion of Computer Records
  • Transmission of records to an external body
  • Cloud storage

The table below contains the retention period that we have assigned to each type of record. This will be adhered to wherever possible, although it is recognised that there may be exceptional circumstances which require documents to be kept for either shorter or longer periods.

Exceptional circumstances should be reported to Justin Clarke, Emma Bullivant or Tim Hughes without delay.

Retention Shedule

Tel: 01332 497 990

Fax: 08449 673 001

Helpdesk: 08449 673 002

solutions@completenetworks.co.uk

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Contact Us

Complete Networks Ltd

The Millhouse Centre

Station Road

Castle Donington

Derbyshire

DE74 2NJ

solutions@completenetworks.co.uk

Tel: 01332 497 990

Fax: 08449 673 001

Helpdesk: 08449 673 002

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