We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy: We, us, our Southfacing Services Limited of 81 Essex Road, Islington London N1 2SF Personal information Any information relating to an identified or identifiable individual Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation Websites www.
We may collect and use the following personal information about you:
This personal information is required to provide services to you. If you do not provide personal information where we ask for, it may delay or prevent us from providing services to you.
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Websites. However, we may also collect information:
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
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 table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|- To provide services to you||- For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or Southfacing Services Limited||For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity||To comply with our legal and regulatory obligations|
|Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Communicating our services and those of selected third parties to:
||For our legitimate interests or those of a third party, ie to inform you of our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards|
|To comply with our legal and regulatory obligations|
We do not control or process any special categories of personal information, and if we were to do so we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). 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 information 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:
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.
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to our ISO accreditation and the audit of our accounts. 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 information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We will not share your personal information with any other third party.
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’). We do not hold or transfer data outside the EEA.
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it. In relation to Tracker Plus and Tracker Plus Directory data please see your service level agreement for data retention periods. In relation to Southfacing Services Limited’s consultancy usually this will be for 10 years. In relation to CV’s received by us we will delete your CV and all details after 6 months of receipt of your CV. If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information 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:
|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|
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information 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 continually test our systems and our servers, which host all of our online services to our clients and are ISO 27001 certified, which means we follow top industry standards for information security.
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.
We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you 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.
We may change this privacy notice from time to time—when we do we will inform you via our Websites and/or you accounts within our Websites.
Our contact details are shown below:
Address: Southfacing Services Limited , 81 Essex Road, Islington London N1 2SF Email: firstname.lastname@example.org Tel: 020 7359 5014