IT Positive Limited are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
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?
IT Positive Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: IT Positive Limited, 3 Little Braxted Hall, Witham Road, Little Braxted. CM8 3EU. For all data matters contact our data representative via email@example.com or via 01376 653115.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
• Communicate with you about our services
• Internal record keeping, including for both pre-sales and post-sales (support) purposes
• Check that you are a registered customer if you call our help desk
• Collect payment from you
• Let you know by email about any changes to our services and website
• Market our products and services to you
• Improve our understanding of the type of customers we are attracting to our services and how they use the services.
• Internal personnel, HR and recruitment purposes
• Regulatory or statutory authority requirements
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data on staff, clients and suppliers, as defined in Article 6 of GDPR
Special categories of data as defined in Article 9 of GDPR where applicable
We have obtained your personal data from you, when subscribing to, or requesting our services, when requesting or subscribing to any of your services, from our website, from personal contact, for example having met and having received a business card, or, in the case of personnel and recruitment purposes, via CV’s or application forms and processes.
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:
|Consent of the data subject;||Request for information from our website and other social media platforms|
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||Processing of invoices, the drawing up of contracts, access to clients systems|
|Processing necessary for compliance with a legal obligation||Processing of Invoices and other financial transactions|
|Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||Data from business cards received at networking and other business events.
Requests for information and contact made from social media, website, and other digital formats.
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
|Processing necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement||Data received from CV’s, employment application forms and other personnel processes.|
|Processing necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent||Data received from CV’s employment application forms and other personnel processes.|
|Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional||Data received from CV’s employment application forms and other personnel processes.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared as follows:
We sometimes need to share your personal information with the partner companies which we use to provide some of our services. We do not allow these companies to use your personal information for any purposes beyond providing our services to you.
If we receive a Court Order requiring us to reveal your identity, we will do so.
If there is a change in the ownership of IT Positive Limited or any of its assets, we may have to disclose personal information to the new owner.
7. How long do we keep your personal data?
We keep your personal data for no longer than necessary. This is a period of seven years, in case of any accounting queries.
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.
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 withdraw your consent to the processing at any time, where consent was your lawful basis for processing the 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
Where personal data is transferred or processed outside the EEA, by third parties as part of the service or contractual obligations we have with clients, relevant safeguards have been checked to ensure GDPR compliancy.
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.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our data controller via firstname.lastname@example.org, by phone to 01376 653115 or in writing to The Data Controller. IT Positive Limited 3 Little Braxted Hall, Witham Road, Little Braxted. Essex. CM8 3EU
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 https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Date modified: 16/05/18