We are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
A controller determines the purposes and means of processing personal data.
A processor is responsible for processing personal data on behalf of a controller.
A natural person.
Categories of 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.
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.
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.
Who are we?
easyNetworks is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are firstname.lastname@example.org.
The purpose of processing your personal data
We use your personal information primarily to enable us to provide you with a service in accordance with your instructions. We also use your personal information for related purposes including identity verification, administration of files, updating existing records if you have instructed us previously, analysis to help improve our management, and for statutory returns and legal and regulatory compliance. The information will be held in hard copy and/or electronic format.
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.
What data do we collect?
We collect and retain personal contact information (such as name, address, telephone number and email address). We do not collect any special categories of data.
You have provided us with this data directly by filling in forms or corresponding with us by post, telephone, email or otherwise.
What is our legal basis for processing your data?
Performance of Contract – this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legitimate Interest – this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared with internal Processors and third party suppliers where appropriate.
There may be occasions when we are under a legal duty to share personal information with law enforcement or other authorities, including the Information Commissioner. If we are required to disclose information to the National Crime Agency, we may not be able to tell you that a disclosure has been made. We may have to stop working for you for a period of time and may not be able to tell you why. We cannot be held liable for any loss you suffer due to delay or our failure to provide information in these circumstances.
How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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.
Providing us with your personal data
We require your personal data as necessary to enter into a contract and provide you with goods and services.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the below 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 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).
Transfer of data abroad
We do not transfer personal data outside the EEA.
Automated decision making
We do not use any form of automated decision making in our business.
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.
Keeping your data safe
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We use a private, secure, cloud computing service to assist us in processing and protecting your information and keeping it secure from the risks of cybercrime and fraud. All IT providers we use are subject to strict confidentiality agreements and we will ensure that they meet GDPR obligations in relation to the service they provide to us.