1. Scope
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2. Responsibilities
2.1 The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Empower IT Solutions Ltd collecting/processing their personal data.
2.2 All Employees/Staff of Empower IT Solutions Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
Empower IT Solutions Ltd t\a SMY IT Services We specialise in the provision of IT consultancy, strategy and support to commercial businesses. Our service offerings are wide ranging and tailored to each client. We have in depth experience in the support of many hardware and software vendors and are very familiar with the issues that can be faced by our clients.
|
Full name of legal entity: |
Empower IT Solutions Ltd |
|
Other trading names: |
SMY IT Services |
|
Email address: |
|
|
Postal address: |
Cedar House, Mill Hill, Capel St Mary, Ipswich, Suffolk. IP 9 2JE |
|
Telephone number: |
(+44) 01473 557 203 |
This privacy notice aims to give you information on how Empower IT Solutions Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Empower IT Solutions Ltd is the controller and responsible for your personal data (collectively referred to as “company”, “we”, “us” or “our” in this privacy notice).
Our Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DOP who can be contacted directly using the details above.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The personal data we may collect from/process on you includes, Name, Contact Details, Cookies, IP Address.
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 follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status and job title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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.
• Profile Data includes any your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
The personal data we collect will be used for the following purposes:
• To provide IT services to clients
• To provide technical support to our Clients and their staff or members
• Identification for password resets
• Billing Purposes
• Carry out technical administration
• Enable Customer administration
• Allow the marketing of services or events relevant to individuals or businesses
• Identify areas where services can be improved
Our legal basis for processing for the personal data:
• Contractual basis for providing a service
Any legitimate interests pursued by us, or third parties we use, are as follows:
• Commercial Interests
The special categories of personal data concerned are:
• Not Applicable
3.2 Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Empower IT Solutions Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting the DPO and requesting a Consent Withdrawal form.
3.3 Disclosure
Beyond our legal basis and legitimates interests for processing your personal data, Empower IT Solutions Ltd will not pass on your personal data to third parties without first obtaining your consent.
3.4 Retention period
Empower IT Solutions Ltd will process personal data for 7 years or as long as required by the terms of a contract, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
3.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you and to check that we are lawfully processing it.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing, the conditions being a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to object – you have the right to object to certain types of processing such as direct marketing, 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Empower IT Solutions Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
• Right to withdraw consent at any time – where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
3.6 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Empower IT Solutions Ltd (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and the Empower IT Solutions Ltd Data Protection Officer.
3.7 Privacy statement
Read more about how and why we use your data, below.
4. Online privacy statement
Personal data Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘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”.
How we collect your personal data
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies..
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as (but not including) analytics, advertising networks; and search information providers, as well as Contact, Financial and Transaction Data from providers of technical, payment and delivery services and Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
How we use your information
This privacy notice tells you how we, Empower IT Solutions Ltd, will collect and use your personal data.
Why does Empower IT Solutions Limited need to collect and store personal data?
In order for us to provide you with a service and/or the best experience on our website, we need to collect personal data. This may include correspondence purposes and/or detailed service provision to existing clients. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Empower IT Solutions Ltd will contact you for additional consent, utilizing double opt-in. Most commonly, we will therefore, 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 and/or where we need to comply with a legal or regulatory obligation.
Will Empower IT Solutions Ltd share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Empower IT Solutions Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Empower IT Solutions Ltd’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or unless we are legally required to do otherwise, or within legal basis and legitimates interests.
How will Empower IT Solutions Ltd use the personal data it collects about me?
Empower IT Solutions Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Empower IT Solutions Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases 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..
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, |
(a) Identity (b) Contact (c) Technical |
(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 (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform |
|
To use data analytics to improve our website, products/services, marketing, |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to |
|
To make suggestions and recommendations to you about goods or services that |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Under what circumstances will Empower IT Solutions Ltd contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorized access or disclosure.
Can I find out the personal data that the organisation holds about me?
Empower IT Solutions Ltd at your request, can confirm what information we hold about you and how it is processed. If Empower IT Solutions Ltd does hold personal data about you, you can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Empower IT Solutions Ltd or a third party, information about those interests. · The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
5. Our legal obligations
We will share specific and relevant information with law enforcement and
government agencies or public bodies where we are legally required to do so.
Examples may include:
• The prevention or detection of crime and fraud
• The apprehension or prosecution of offenders
• The assessment or collection of tax or duty owed to customs and excise
• Sharing in connection with legal proceedings
• Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm
We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency that affects you.
Sharing information with our contractors and suppliers
There are some cases when we will share your information to support legitimate business purposes. We do this to make sure that we can meet your needs, and to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our contractors and suppliers
to allow them to carry out duties on our behalf or to meet contractual obligations we may have. For example, we may share information to enable our maintenance contractors to make appointments with you to carry out repairs and/or deliver services.
Keeping your information secure
We store personal information both electronically and in paper form. We implement security policies, processes and technical security solutions to protect the personal information we hold from:
• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss.
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors etc) act on your behalf, we will take steps to make sure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know. Employees and third parties who have access to, or are associated with the processing of, your personal information will be required to ensure compliance with the GDRP and Data Protection Act and make reasonable efforts to safeguard it.
What forms of ID will I need to provide in order to access this?
Empower IT Solutions Ltd accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months).
Promotional offers from us – We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing – We will get your express opt-in consent before we share your personal data with any company outside of our group of companies for marketing purposes.
Opting out – You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
6. Our website
When accessing our website/s, Empower IT Solutions Ltd will collect standard internet log information for statistical purposes and to provide the website experience. Details of how we do this are on our Privacy Policy page.
• We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited
• When we collect personal information, for example via an online form, we will explain what we intend to do with it
• Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
7. Document Owner and Approval
The Data Protection Officer is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.
8. Change History Record
This document is reviewed at least annually.