Privacy Policy

1. INTRODUCTION

We are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

In this notice, "we", "us" and "our" refer to Avonside Safety Management LTD. For more information about us, see section 8.

2. HOW WE USE YOUR PERSONAL DATA

In this section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; (if applicable)
(c) the purposes for which we may process personal data; and the legal bases of the processing.

We may process your account data ("account data"). The account data may include your name, postal address, telephone number and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our business.

We may process your personal data that is provided in the course of the use of our services ("service data"). The service data may include may include your name, postal address, telephone number, email address and specified username. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our business.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us ("transaction data"). The transaction data may include your contact details, your card details and the transaction details including account number and sort code. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.

We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. PROVIDING YOUR PERSONAL DATA TO OTHERS

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose project speciation’s to subcontractors insofar as reasonably necessary for project development providing the necessary consent from you or your employer is requested and agreed.

All financial transactions at this stage our handled by our internal payment services. We will share transaction data with our payment services only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

In addition to the specific disclosures of personal data set out in this section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. RETAINING AND DELETING PERSONAL DATA

This section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data already obtained as follows:

Any personal data (see section 2) will be retained for a minimum period of 5 years following 24/05/2018, and for a maximum period of 10 years following 24/05/2018.

We will retain your personal data not already obtained as follows:

Any personal data (see section 2) will be retained for a minimum period of 5 years following date data is received, and for a maximum period of 10 years following date data is received.

Notwithstanding the other provisions of this section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. AMENDMENTS

We publish changes to this notice on our website at esafetysystem.com

We will notify you of any changes to this notice which may affect you by email or post.

7. YOUR RIGHTS

In this section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

the right to access;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent.

You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal

data is:

consent; or

that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section 7

8. OUR DETAILS

Our full legal name is Avonside Safety Management LTD

We are registered in England and Wales under registration number 03765280 and our registered office is at St Chloe Lane, Amberley, Stroud, Glos GL5 5AS.

Our principal place of business is at Avonside Safety Management LTD, Unit 10 Moons Park, Burnt Meadow Road, Moons Moat, Redditch, B98 9PA.

You can contact us:

by post, to the postal address given above;
using our website contact form at esafetysystem.com;
01527 864 136; or
info@esafetysystem.com

9. DATA PROTECTION OFFICER

Our data protection officer's contact details are: Nick Lane – e-Safety System

Data Retention Policy

1. INTRODUCTION

This policy sets out the policies and procedures of Avonside Safety Management LTD (the "company") with respect to [the retention, archiving and deletion of data, whether in hard copy or digital form, and including personal data]

The company is subject to a range of statutory obligations in relation to the retention of data. On the one hand, the company is obliged to retain some classes of data for a minimum period. On the other hand, it is a fundamental principle of data protection law that personal data should be only retained for so long as required. Moreover, the retention of some classes of data may represent an unnecessary security risk. For these reasons, the company recognises the importance of formulating clear and specific policies in relation to data retention.

2.DEFINITIONS

In this policy:

(a) "appointed person" means [the individual primarily responsible for handling data retention, archiving and deletion by the company], being [the data protection officer of the company];

(b) "data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

(c) "data processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

(d) "data subject" means an identified or identifiable natural person; 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;

(e) "deletion" means [the permanent and irreversible deletion of data from all relevant databases and storage media in the possession or control of the company including, where necessary to ensure the deletion of the data, the destruction of the relevant storage media]; and

(f) "personal data" means any information relating to a data subject.

3.DATA RETENTION, ARCHIVING AND DELETION

The company must [archive and delete] [data in its possession and/or control] in accordance with schedule 1 (Data retention periods), save as set out in this section 3.

Notwithstanding the archiving rules set out in this policy, the company may retain non-archived copies of data to the extent that the data is reasonably required in non-archived form for:

(a) the fulfillment of any legal or contractual obligations of the company; and/or

(b) the establishment, exercise or defence of any legal claims.

The company must not delete data to the extent that:

(a) the company has a legal obligation to retain the data;

(b) the company has a contractual obligation to retain the data (providing that such contractual obligation is not overridden by any legal obligation to delete the data); and/or

(c) the retention of the data is reasonably required for the establishment, exercise or defence of any legal claims (providing that such requirement is not overridden by any legal obligation to delete the data).

3.4 The company must not archive or delete any records to the extent that [the legal department of the company] has issued [a legal hold instruction] in relation to such records.

4.DATA SUBJECT TO CONTRACTUAL DELETION OBLIGATIONS

The following categories of data processed by the company are or may be subject to contractual deletion obligations:

(a) confidential information disclosed to the company by another person under a non-disclosure agreement or the confidentiality provisions of a contract; and

(b) [personal data with respect to which the company acts as a data processor].

Any deletion obligations with respect to confidential information will be set out in the relevant contract, and may vary from contract to contract. The company must comply with those obligations.

If the company acts as a data processor with respect to personal data, the law requires that the processing contract includes an obligation upon the company to delete the personal data after the end of the provision of services relating to the processing, save to the extent that the law requires storage. All personal data that the company processes on behalf of a data controller will be subject to appropriate deletion obligations taking the law into account, and the company must comply with those obligations.

To ensure compliance with its contractual deletion obligations, the company shall maintain a register of those obligations identifying, with respect to each relevant contract, [the data to be deleted and the dates for deletion of that data].

5. DEFAULT ARCHIVING AND DELETION METHODS

Data must be archived by the company in the company server [, save to the extent that specific archiving methods are provided for in schedule 1 (Data retention periods)].

Data must be deleted by the company and removed from the company server [, save to the extent that specific deletion methods are provided for in schedule 1 (Data retention periods)].

6.REVIEWING AND UPDATING THIS POLICY

[The appointed person] shall be responsible for reviewing and updating this policy.

This policy must be reviewed and, if appropriate, updated [annually] on or around 1st December.

This policy must also be reviewed and updated on an ad hoc basis if reasonably necessary to ensure:

(a) the compliance of the company with applicable law, codes of conduct or industry best practice;

(b) the security of data stored and processed by the company; or

The following matters must be considered as part of each review of this policy:

(a) changes to the legal and regulatory environment;

(b) changes to any codes of conduct to which the company subscribes;

(d) any new data collected by the company;

(e) any new data processing activities undertaken by the company; and

(f) any security incidents affecting the company.

Data Protection Information Notice for Customers

INTRODUCTION

We are committed to safeguarding the privacy of all individuals whose personal data we store and process; in this notice we explain how we will handle your personal data.

This notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

In this notice, "we", "us" and "our" refer to Avonside Safety Management LTD. For more information about us, see section 9.

HOW WE USE YOUR PERSONAL DATA

In this section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;(if applicable)

(d) the legal bases of the processing.

The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.

The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

PROVIDING YOUR PERSONAL DATA TO OTHERS

We may disclose project speciation’s to subcontractors insofar as reasonably necessary for project development providing the necessary consent from you or your employer is requested and agreed.

RETAINING AND DELETING PERSONAL DATA

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data already obtained as follows:

(a) Any personal data (see section 2) will be retained for a minimum period of 5 years following 24/05/2018, and for a maximum period of 10 years following 24/05/2018.

We will retain your personal data not already obtained as follows:

(a) Any personal data (see section 2) will be retained for a minimum period of 5 years following date data is received, and for a maximum period of 10 years following date data is received.

4.5 Notwithstanding the other provisions of this section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

SECURITY OF PERSONAL DATA

We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

The following personal data will be stored by us in encrypted form.

You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You should ensure that your passwords used to access our software and IT systems are not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the passwords confidential and we will not ask you for your passwords (except when you log in to our software and IT systems).

AMENDMENTS

We publish changes to this notice on our website at esafetysystem.com

We will notify you of any changes to this notice which may affect you by email or post.

YOUR RIGHTS

the right to access;

the right to rectification;

the right to erasure;

the right to restrict processing;

the right to object to processing;

the right to data portability;

the right to complain to a supervisory authority; and

the right to withdraw consent.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

OUR DETAILS

Our full legal name is Avonside Safety Management LTD

We are registered in England and Wales under registration number 07375382764 and our registered office is at 4 Worcester Close, B75 5UA

Our data protection officer's contact details are: Nick Lane – Nick.Lane@Avonside-sm.com

Cyber Security Incident Response Policy

1.INTRODUCTION

Cyber security incidents are a significant risk to e-Safety System (the "company").
This policy describes how to recognise a breach, who to report it to and what happens next.
Cyber breaches are becoming more common and more expensive to fix.
Responding as fast as possible is key, so please read this document and keep it to hand for when it is needed

2.WHO YOU SHOULD CONTACT IF YOU THINK THERE'S BEEN CYBER SECURITY INCIDENT?

The person primarily responsible for coordinating the company's response to a cyber security incident is Nick Lane (the "incident coordinator").

3.WHAT MIGHT INDICATE THAT THERE HAS BEEN A BREACH?

The following may indicate that a cyber security breach has occurred:

(a) you have made a mistake, clicked on a link you shouldn’t have, or your device anti-virus software or browser is reporting that malware has been detected;

(b) an inability to access data or devices, or unusual behavior, possibly accompanied by a ransom message;

(c) spikes in network traffic, database requests, or the size of HTML responses (which may be observed by the IT team); and

(d) employees that you know are not present have accessed or edited files.

4.WHAT DO I DO IF I MAKE A MISTAKE?

If you have made a mistake that may have caused a cyber security breach then the most important thing is time:

(a) do not attempt to solve the problem by yourself;

(b) you must report the problem to the incident coordinator immediately

(c) you will need to be able to tell them what device, how it is connected to the company's IT systems, and what company data it contains;

(d) if you made a mistake using your own computer or phone, while it is connected to the company's systems, or contains the company's data, you must still contact the incident coordinator for support; and

(e) making a mistake is not system misuse, but failing to report one is.

5.I'M THE INCIDENT COORDINATOR, WHO DO I NOTIFY, WHAT ARE THEIR ROLES?

If you notice a cyber security breach indicator, or have made a mistake, contact the incident coordinator. The following people should be notified by the incident coordinator if the breach is confirmed:

(a) technical incident response team: Nick Lane;

(b) The data protection officer: Nick Lane;

If the cyber security breach includes personal data then the Information Commissioner's Office may need to be informed, typically within 72 hours. Data subjects may also need to be informed.

6. WHAT ARE THE RESPONSIBILITIES OF THE MEMBERS OF THE INCIDENT RESPONSE TEAM?

Technical incident response personnel should establish:

(a) what has happened;

(b) which parts of which systems are affected;

(d) what needs to be done to remove any malware; and

(e) what feedback the company need to improve their security in future.

The [data protection officer] should establish whether personal data has been compromised, and if so, how much? Notify as required.

The [data protection officer] should communicate with insurers to obtain support and ensure that technical teams know what evidence they must collect to document the incident for the claim. The insurer may wish for the police to be informed.

Communications should begin preparing communications to employees, customers and the press about the ongoing incident – a "well handled" breach, in the eyes of customers, will be a well-communicated breach. Communications have to be available as soon as senior management require them and employees need to know not to tweet.

Senior management should collect enough information to make strategic decisions during the incident.

Privacy Policy

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