1. POLICY STATEMENT
1.1. Eliga Services (“the Company”) is committed to protecting the privacy and security of your personal information.
1.2. The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This Policy sets out our obligations and your rights in accordance with the General Data Protection Regulation (“GDPR”), which has been retained in the UK by the Data Protection Act 2018.
1.3. This Policy applies to current and former employees, workers and contractors. This Policy does not form part of any contract of employment or other contract to provide services. We may update and amend this policy at any time.
1.4. It is important that you read this policy, together with any other Privacy Notice we may provide to you, so that you are aware of how and why we are using such information.
2. DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
2.1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data includes first name, maiden name, last name, title
- Contact data includes email address and telephone numbers
- Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Usage data includes information about how you use our website and services
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences
2.2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- complete our enquiry form on our website
- contact us by telephone or email to seek a quote; and
- when you instruct us to provide services for you by telephone or email and you
become our client
- Third parties or publicly available sources. We may receive personal data about you from various third parties including Technical Data from analytics providers such as Google based outside the UK or the EU.
2.3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
2.4. Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. We do not process your data for automated decision-making or profiling purposes.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To respond to your enquiry raised using our enquiry form on our website||(a) Identity
(a) Necessary for our legitimate interests (for running a business)
(d) Marketing and Communications
(a) Performance of a contract with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
3. DATA SHARING
3.1. We may have to share your data with third parties, including clients and third-party service providers.
3.2. We require third parties to respect the security of your data and to treat it in accordance with the law.
3.3. We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
3.4. If we share personal data with third parties (including those based outside the UK), this is identified in the Privacy Notice relevant to your employment or engagement.
4. HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. DATA SECURITY
5.1. We have put in place the following measures to protect the security of your information:
5.1.1. Personal data is stored within our Microsoft SharePoint platform, the shared drive and on the hard drives of individual Company laptops. It is only accessible by Company employees who have individual logins and passwords.
5.1.2. Laptop hard drives are encrypted.
5.1.3. Where appropriate, information sent by email is encrypted.
5.1.4. Our systems are regularly backed up into cloud storage.
5.1.5. All Company laptops can be disabled remotely by Apple on our instruction.
5.1.6. Personal data contained in hard copy format is kept in a locked cupboard on Company premises.
5.1.7. The Company premises may only be accessed by authorised personnel with a door key and passcode.
5.1.8. Some information, such as next of kin and emergency contact information, is held by Human Resources only.
5.2. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
5.3. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
5.4. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
6. DATA RETENTION
6.1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6.2. Details of retention periods for different aspects of your personal information are set out in the Privacy Notice relevant to your employment or engagement.
6.3. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6.4. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
7. RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
7.1. Your duty to inform us of changes:
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
7.2. Your rights in connection with personal information:
Under certain circumstances, by law you have the right to:
7.2.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
7.2.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
7.2.3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
7.2.4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
7.2.5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
7.2.6. Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Privacy Manager in writing.
7.3. No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
7.4. What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
8. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Privacy Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
9. DATA PRIVACY MANAGER
9.1. We have appointed a Data Privacy Manager to oversee compliance with this Policy and our Privacy Notices. They can be contacted at:
9.2. If you have any questions about this Policy, our Privacy Notices or how we handle your personal information, please contact the Data Privacy Manager.
9.3. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
10. CHANGES TO THIS POLICY
We reserve the right to update this Policy at any time, and we will provide you with a new Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
What Are Cookies
For more general information on cookies see the Wikipedia article on HTTP Cookies.
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The Cookies We Set
Forms Related Cookies
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Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
Hopefully, that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.
However, if you are still looking for more information, please do contact us through one of our preferred contact methods:
Phone: 0345 2606 206
If you have a complaint about data protection at Eliga Services Limited, please contact our data protection officer at firstname.lastname@example.org. Alternatively, you may get in touch with our supervisory authority for data protection compliance at: www.ico.org.uk:
Information Commissioner’s Office Wycliffe House
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)