Confidentiality Statement
This policy contains information confidential and proprietary to the Purple Wellies Ltd. This document contains information that is confidential or otherwise protected from disclosure and shall not be disclosed without prior approval.
Document version control
The document owner is Dave Harris.
Date | Current Version | Comment | Next review date | Author | Status |
24/4/2020 | 1 | Policy created | DH/KA | Approved |
Document history control
Date |
Version |
Comment |
Author |
Approver |
Status |
24/4/2020 |
1 |
Policy created |
DH/KA |
Approved |
Contacts
Name |
Role |
Company |
Contact |
Dave Harris |
Operations Director |
Purple Wellies |
info@purplewellie.com |
Definitions
The definition of the Data Controller, Data Processor, Data, Personal Data, Processing is in accordance with the Data Protection Act 2018 and the General Data Protection Regulation.
“ICO” means the information commissioner’s office.
[1] Introduction
The definition of the Data Controller, Data Processor, Data, Personal Data, Processing is in accordance with the Data Protection Act 2018 and the General Data Protection Regulation.
“ICO” means the information commissioner’s office.
[2] The information We may hold about You
[1] What Personal Data do We collect or process?
For most of the various exterior cleaning services and other cleaning related services the Personal Data processed as per 2.2. below.
[2] Why do we collect this information?
We use the Personal Data for purposes listed below for Our residential clients by collecting the Personal Data as the Data Controller and Data Processor where we operate on behalf of a business except where role differs see table below in 2.2.1 including our employee details as Data Controllers.
[1] When do we process this information (no collection)?
In some of the services which We provide the Personal Data is collected by Our client which We are then provided to process on behalf of them for this We are the Data Processor see table below in 2.2.1
Subject | Role | Purpose and type of activities | Lawful basis for processing | Special Category purpose | Personal Data |
External cleaning Services | (i)Controller if collecting or (ii) Processor on behalf of the client if they collect | (i) To arrange installations, orders and quotes (ii) To refer to finance provider | Performance of a contract | Not applicable | First name, surname, status, address, phone, email, IP address.
|
Employees or representatives | Controller | To carry out Human resources compliance checks | Performance of a contract | Consent / Legal claims / vital interest | National insurance number, first name, surname, status, date of birth, address, phone, email, driving license, utility, passport. Special category: racial or ethnic origin, convictions, medical. financial information, litigation information, and housing. |
Deal with regulatory or legal queries | Controller | To contact legal or regulatory authority under a legal obligation
| Legal obligation | Not applicable | First name, surname, address, phone, email or any other details as requested. |
Marketing and advertising including online, mail. | Controller | To provide marketing material including newsletter or blogs (e.g. marketing- by email) or targeted marketing (e.g. adverts – direct marketing) under any preferences consented which may be of interest to you unless opted out. | Consent / legitimate interest | Not applicable | First name, surname, address, phone, email. |
[2] How is this information collected?
We may collect Your details from our contact us form, direct emails, enquiries or any business client. Any Website tracking information related to device specific, collecting information about e.g. web analytics etc if applicable.
[3] Use of the information collected?
The Personal Data is used to contact You via email or other means about Our service provision under section 2.2 above and to identify You when You engage with Us. Our partners who are instructed by Us on Our behalf in delivering any part of service to You in 2.2 above. For marketing Our services to You except where You have withdrawn or opted out to receive any marketing from Us.
Any third party which We use for Data Processing will only process for example the email, until such time either the Personal Data is deleted on exit of a contract or a right which is exercised e.g. right to erase or withdraw of consent.
[3] Cookies, web analytics traffic
A Website may have number of small scripts running in the background to capture web traffic data or retain session information about You. Our Website may use the listed cookies below:-
Type | Company | Use |
Google Analytics | Web analytics online service which tracks and reports website traffic. | |
Google my business | is an online business listing and profile platform. | |
Google ad words | is an online advertising platform. | |
Google Maps | is a web mapping service developed by Google. | |
Facebook pixels | is code that you place on the website to track website traffic. | |
Linkedin pixels | is code that you place on the website to track website traffic. |
You may be able to disable some cookies on Our Website under their browser settings and it may affect the way a Website operates. You can find further information about cookies at www.allaboutcookies.org
[4] Third parties
We work with a few trusted third parties below delivering any of the services mentioned above in section 2.
Supplier | Services |
DP Marketing | Webhosting |
Credible (or other) | Interest free credit/loan independent company financing for clients. |
Mail chimp | Marketing software |
Facebook/Linkedin/Twitter | Social media |
Note: We bank with U.K. banks.
[5] Marketing
We may contact You from time to time and send You details of services that We provide which may be of interest to You. We may share Your information with other third parties to contact You about services which may be of interest to You with inhouse marketing. Any external marketing lists used shall be subject to approved consents where applicable. If You do not wish to receive such requests in the future, please contact Us to withdraw.
[6] Your rights
As a client You have several rights in relation to Personal Data some are listed below. Where applicable We will respond to the above requests within thirty (30) days or notify as to who should be responding.
[1] Subject access requests
If You wish to submit a subject access request, on the information We may hold about You then please email info@purplewellie.com Where We are acting as the Data Controller of the Personal Data We will respond. However, where We are acting as the Data Processor or a third party We will pass Your request onto the relevant Data Controller to respond directly. There is no charge of this except where such request is excessive it may be chargeable.
[2] Inaccurate Personal Data
Where We collect or use the Personal Data and which You believe is incorrect, please contact Us with a request to amend the Personal Data.
[3] Request to withdraw, erase and portability of Personal Data
If You wish to submit a request in relation to withdrawing consent, erase or port Your Personal Data We hold on You then please contact Us.
The ICO guidelines provide that some rights may not apply right to object (excluded under contact, legitimate interest or public tasks), erase (excluded under legal obligation or public tasks), portability (excluded under legal obligation, vital interest, public tasks, legitimate interests).
[7] Retention and deletion of Personal Data
We will retain records no longer than they are required in accordance with Our retention policy or as up to 7 years if You withdraw/erase earlier then the Personal Data will be deleted exceptions for example legal etc reasons held for longer. On exit of a service for example Website hosting with database, We will delete the Personal Data collected in accordance with Our retention policy.
[8] Personal Data outside the EEA
If any of website design or hosting services are provided outside of the EEA and Personal Data may be transferred by Us in order to provide You service to You in 2.2 above. Where We transfer any Personal Data outside the European Economic Area (EEA) this will be subject to either model agreements or binding corporate rules to ensure that higher level of data privacy are applied.
[9] Links to other websites
Our Website may contain other website links or content for interest. On entering the other website, We will have no control once You exit Our Website. We exclude all responsibility and liability for any Personal Data which You may submit. If You are not sure about entering Personal Data on these other websites, please review their privacy policy.
[10] Disclosure of information
We reserve the right to disclose collected Personal Data or any other supporting information in response of a court order, legal action, where consent is given, acquisition, regulator body where such disclosure is required law or regulation.
[11] Contacting Us and Complaints
If You have any questions in relation to this privacy policy or data privacy please contact the Data Protection Officer at info@purplewellie.com.