1. Introduction
This Policy sets out the obligations of 3Spires Safety Professionals Ltd (“the Company”) regarding data protection and the rights of Clients, Client employees and relevant 3rd Parties in respect of their personal data under the General Data Protection Regulation (“the Regulation”).
The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed always by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
3. Lawful, Fair, and Transparent Data Processing
The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:
a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes, either directly or through their employer;
b) processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which the controller is subject;
d) processing is necessary to protect the vital interests of the data subject or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, where the data subject is a child.
4. Processed for Specified, Explicit and Legitimate Purposes
4.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This may include personal data received directly from data subjects (for example, copies of passports) and data received from third parties.
4.2 The Company only processes personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.
5. Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 4, above.
6. Accuracy of Data and Keeping Data Up to Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
7. Timely Processing
The Company shall not keep personal data for any longer than is necessary considering the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.
8. Secure Processing
The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.
9. Accountability
9.1 The Company’s data protection officer is Joshua Payne, Director, 3Spires Safety Professionals Ltd.
10. Privacy Impact Assessments
The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall be appropriate for a company our size.
11. Keeping Data Subjects Informed
11.1 The Company shall ensure that the following information is provided to every data subject when personal data is collected:
a) Details of the Company including, but not limited to, the identity of Joshua Payne its Data Protection Officer;
b) The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
c) Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
d) Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
e) Where the personal data is to be transferred to one or more third parties, details of those parties;
f) Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 24 of this Policy for further details concerning such third country data transfers);
g) Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
h) Details of the data subject’s rights under the Regulation;
i) Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
j) Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
k) Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
l) Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
12. Data Subject Access
12.1 A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
12.2 All subject access requests received must be forwarded to Joshua Payne the Company’s data protection officer.
12.3 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
13. Rectification of Personal Data
13.1 If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
13.2 If any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
14. Erasure of Personal Data
14.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
a) It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning data subjects’ rights to object);
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased for the Company to comply with a legal obligation.
14.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
14.3 If any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
15. Restriction of Personal Data Processing
15.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
15.2 If any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
16. Data Portability
16.1 The Company processes personal data using automated means.
16.2 Where data subjects have given their consent to the Company to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).
16.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following formats:
a) E-Mail /Electronic
b) Written/Paper
16.4 Where technically feasible, if requested by a data subject, personal data shall be sent directly to another data controller.
16.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
17. Objections to Personal Data Processing
17.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
17.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
17.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
18. Automated Decision-Making
18.1 If the Company uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
18.2 The right described in Part 19.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
b) The decision is authorised by law; or
c) The data subject has given their explicit consent.
19. Profiling
Where the Company uses personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).
20. Personal Data
The following personal data may be collected, held, and processed by the Company:
a) Name
b) Date of Birth
c) Gender
d) Business/Company Name Where Employed/Self Employed/Contractor etc.
e) Job Title
f) Profession
g) Training accreditations
h) Contact Information such as E-mail Addresses and Telephone No’s
i) Demographic Information such as Post Code, Preferences and Interests
j) Qualifications, including Year(s) obtained.
k) Passport data/images
l) Any other Data provided on a CV or given in Telephone Conversations relevant to the conduct of 3Spires Safety Professional’s legitimate Business Interests.
21. Data Protection Measures
The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
a) All emails containing personal data must be as secure as possible.
b) Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely.
c) Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
d) Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
e) Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
f) Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
g) Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient using an appropriate delivery System to record safe receipt.
h) No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Joshua Payne, Director, 3Spires Safety Professionals Ltd
i) All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
j) No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Joshua Payne, Director, 3Spires Safety Professionals Ltd.
k) Personal data must be handled with care always and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
l) If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period, the user must lock the computer and screen before leaving it;
m) No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Joshua Payne, Director, 3Spires Safety Professionals Ltd and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
n) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
o) All personal data stored electronically should be backed up every 2 Weeks with backups stored onsite. All backups should be encrypted.
p) All electronic copies of personal data should be stored securely using passwords and data encryption;
q) All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols All software used by the Company is designed to require such passwords
r) Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
s) Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Joshua Payne, Director, 3Spires Safety Professionals Ltd to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked at least Annually.
22. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
a) All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
b) Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data to carry out their assigned duties correctly shall have access to personal data held by the Company;
c) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
d) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
e) Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
f) The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
g) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this
Policy by contract
h) All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that all their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
i) Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
23. Transferring Personal Data to a Country Outside the EEA
23.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
23.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
a) The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
b) The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
c) The transfer is made with the informed consent of the relevant data subject(s);
d) The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
e) The transfer is necessary for important public interest reasons;
f) The transfer is necessary for the conduct of legal claims;
g) The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
h) The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who can show a legitimate interest in accessing the register.
24. Data Breach Notification
24.1 All personal data breaches must be reported immediately to the Company’s data protection officer.
24.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
24.3 If a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 25.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
24.4 Data breach notifications shall include the following information:
a) The categories and approximate number of data subjects concerned;
b) The categories and approximate number of personal data records concerned;
c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
d) The likely consequences of the breach;
e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
25. Implementation of Policy
This Policy shall be deemed effective as of 25th May 2018 No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
Who we are
This website is owned and operated by 3spires Safety Professionals Ltd.
Our website address is: https://3spiressafety.com.
What personal data we collect and why we collect it
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms
This website uses contact forms to allow you to submit emails to us. When doing so you will need to accept a checkbox that agrees to use storing your email and information in our email servers.
Cookies
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If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
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Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
This website uses Google Analytics to provide our analytics and reporting services so we can estimate our traffic and website performance.
This requires two Google Analytics cookies.
You can opt-out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on.
You may also wish to refer to this website for additional information about disabling cookies from your browser: http://www.allaboutcookies.org/manage-cookies/.
Who we share your data with
We do not share or sell your personal data to other organizations for commercial purposes, except to provide the products or services you’ve requested, when we have your permission or if we need to comply with law enforcement authorities.
We share information with only a few third parties that include.
Google Analytics – No personal data is shared.
We will not share your data with anyone else unless legally obligated to do so.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
Contact information
Visit our contact page.
Additional information
How we protect your data
We ensure your data is secure at all times and processed over a secure connection. Always look for the padlock in the browser address bar to check if an SSL certificate is installed.
We only load our website over https only avoiding insecure connections.
What data breach procedures we have in place
If there is a data breach we commit to abiding by the GDPR regulations for informing those affected within 72 hours.
What third parties we receive data from
We receive data from Google Analytics that helps us determine the best performing content, times of the day etc, however, we do not collect any personal or private information. Everything is anonymized and gives us a holistic view instead of data on individuals.
Use of External Links
This website may contain links to different websites.
We cannot guarantee the accuracy of the information found at any external sites.
Any information on external websites we link to cannot be considered an endorsement by us.
Policy Changes
We reserve the right to update the privacy policy at any time with or without prior notice.
However, be assured that if the privacy policy changes in the future, we will not use the personal info you submitted to us under this policy in a way that is materially inconsistent with the existing version, without your prior consent.