John R Cox – DATA PROTECTION PRIVACY NOTICE

Purpose

This Notice outlines the data protection policies and procedures we have adopted and to which we abide to ensure we are GDPR compliant.  The purpose of this Notice and any other documents referred to in it, is to clearly list and identify the legal requirements, procedures and rights which must be established when we obtain, process, transfer and/or store your personal data. This Notice will assist you in understanding the obligations, responsibilities and rights which arise from the Data Protection Laws.


Introduction

Everyone has rights regarding the way in which their personal data is handled. To operate efficiently we need to collate and use information about the people with whom we work. This includes current, past and prospective employees, clients, and others with whom we communicate.

We regard the lawful and correct treatment of personal information as integral to successful operation and to maintaining the confidence of the people we work and communicate with. To this end we fully endorse and adhere to the principles of the relevant Laws.

We are registered as a Data Controller on the Register kept by the Information Commissioner’s Office.


Definitions in this Privacy Notice

Data:

Information stored electronically, on a computer, server or in certain paper-based filing systems.

Data Controller:

John R Cox has determined the purposes for which, and the way, that your Personal Data is processed. The Data Controller has overall responsibility for compliance with the Data Protection Laws.  Any questions about the operation of this Notice or any concerns that the Notice has not been followed should be referred to Kay Cox at John R Cox, Portman’s Walk, Ipswich, IP1 2DW.

Privacy Manager:

Kay Cox is the appointed officer who is responsible for awareness-raising, and informing and advising the Data Controller

Data Processor:

Any person or organisation that is not a Data User that processes personal data on our behalf and in accordance with our specific instructions. Our staff will be excluded from this definition but, the definition could include suppliers who handle personal data on our behalf.

Data Subjects:

All living individuals about whom we hold Personal Data. All Data Subjects have legal rights concerning the processing and storage of their personal information.

Data Users:

Our employees whose work involves accessing your Personal Data. Data users are responsible for the proper use of the data they process and must protect the data they handle in accordance with this Notice.

The Enactments:

The Data Protection Act 1998 (the Act) up to and until 25 May 2018 after which The General Data Protection Regulations 2017 (GDPR) will apply, both of which regulate the way in which all Personal Data is held and processed.

Personal Data:

Information which can be used to directly or indirectly identify a living individual.

Processing:

Any activity in which the data is used, including (but not limited to) obtaining, recording, organising, amending, retrieving, using, disclosing, erasing, destroying and/or holding the data. The term “processing” also includes transferring personal data to third parties.

Supervisory Authority:

The Authorised Body which is empowered to govern and manage how the GDPR is implemented and abided by in an EU state.  In the case of the UK the Supervisory Authority is the: Information Commissioner’s Office.

Sensitive Personal Data:

This includes information about a person’s race, ethnicity, political opinions, convictions, religion, trade union membership, physical and/or mental health, and sexual preference. Sensitive personal data can only be processed with the express written consent of the person concerned.


Notice Statement

 In accordance with the GDPR, anyone processing Personal Data must comply with the six principles of good practice. These provide that Personal Data must:

be processed fairly, lawfully and transparently;

only be used for the purpose for which it was collected;

be adequate, relevant and not excessive for the purpose for which it is being processed;

be accurate and kept up-to-date;

not be kept longer than necessary to fulfil the purpose of its collection; and

be kept secure and protected from unauthorised processing, loss, damage or destruction.

Fair, Lawful and Transparent Processing

For Personal Data to be processed lawfully, the basis for the processing must be one of the legal grounds set out in the Enactments. These include, among other things, your written consent to the processing, or that the processing is necessary for the performance of our payroll contract with you.

In the event we collect Personal Data directly from you, this Notice should assist in informing you about:

1.1 The purpose or purposes for which we intend to process your Personal Data.

1.2  The types of third parties, if any, with which we may share or disclose your Personal Data.

1.3  The means with which you can limit our processing and disclosure of your Personal Data.

If we receive Personal Data about you from other sources, we will provide you with this information as soon as possible thereafter.

When sensitive personal data is being processed, additional conditions and securities must be in place to ensure protection.

Processing for Limited Purposes

 During our business, we shall process the Personal Data that we receive directly from you (for example, by you completing forms, sending us papers or from you corresponding with us by mail, phone, email or otherwise) and your Personal Data which we receive from any other source.

We shall only process your Personal Data to fulfil and/or enable us to satisfy the terms of our obligations and responsibilities in our role as your Payroll Provider or for any other specific purposes permitted by the Enactments.  Should we deem it necessary to process your Personal Data for purposes outside and/or beyond the reasons for which it was originally collected, we will contact you first, to inform you of those purposes and our intent and may also apply for your consent.

Adequate, Relevant Non-Excessive Processing

We will only collect and process your Personal Data as required to fulfil the specific purposes of our contract and agreement with you.

Accurate and up to date data

We shall ensure that all Personal Data held is accurate and up to date and will check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. If you become aware that any of your Personal Data is inaccurate, you are entitled to contact us and request that your Personal Data is amended. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

The Timely Processing of the Data

We will not keep Personal Data longer than is necessary for the purpose or purposes for which it was collected. Once Personal Data is no longer required, we will take all reasonable steps to destroy or erase it.

Keeping Your Personal Data Secure

Our employees and contracted personnel are bound to our privacy policies, procedures and technologies which maintain the security of all your Personal Data from the point of collection to the point of destruction.

We maintain data security by protecting the confidentiality, integrity and availability of your Personal Data, and when we do so we abide by the following definitions:

6.1 Confidentiality:

We ensure that the only people authorised to use your personal data can access it. Employees are prohibited from accessing and viewing your personal data unless it is necessary to do so

6.2  Integrity:

We will make certain that your Personal Data is accurate and suitable for the purpose for which it is processed.

6.3  Availability:

We have established procedures which mean only our authorised Data Users should be able to access your Personal Data if they need it for authorised purposes.

We also maintain security procedures which include, but are not limited to:

6.4 Methods of disposal. Paper documents containing Personal Data are shredded and digital storage devices shall be physically destroyed when they are no longer required.

6.5  Data Users shall be appropriately trained and supervised in accordance with this Notice which include requirements that computer monitors do not show confidential information to passers-by and that Data Users log off from or lock their PC/electronic device when it is left unattended.

6.6  Our computers have appropriate password security, boundary firewalls and effective anti-malware defences. We routinely back-up electronic information to assist in restoring information in the event of disaster and our software is kept up-to-date with the latest security patches.

6.7  One or all of the following measures shall be applied to the personal data held; separating the personal data and/or pseudonymisation and/or the encoding of the data

6.8  Our Privacy Manager or will ensure that this Notice is kept updated in response to any amendments to the Law.

We shall take appropriate security measures against unlawful and/or unauthorised processing of personal data, and against the accidental loss of, or damage to, your Personal Data.

We shall only transfer your Personal Data to a Data Processor (a Data User outside our business) if the Processor agrees to comply with our procedures and policies, or if the Processor puts in place security measures to protect Personal Data, which we consider adequate and are in accordance with the Enactments.


How We Will Use Your Personal Data

We will only collect and process your Personal Data to the extent that it is needed to fulfil our operational and contractual needs or to comply with any legal requirements.

We shall access and use your Personal Data in accordance with your instructions and as is reasonably necessary:

  • to provide you with information on any MOT/service due on your vehicle
  • to respond to your requests, queries and problems;
  • to inform you about any changes to our services and related notices, such as security and fraud notices.

Your Rights and Requests Concerning Your Personal Data

We will process and manage all your Personal Data in line with your rights to:

  • request access to any data we hold about you;
  • prevent the processing of your Personal Data for direct-marketing purposes;
  • ask to have inaccurate Personal Data amended;
  • be forgotten, and have all relevant Personal Data erased (subject to our overriding legal obligations);
  • prevent processing which is likely to cause damage or distress to you or anyone else;
  • request certain restrictions on the processing of your Personal Data;
  • not be subject to automated decision making;
  • be notified of a data security breach which affects your rights and freedoms, without undue delay;
  • to make certain requests to us concerning how your Personal Data is managed.

Access and portability requests

You are entitled to request access to your Personal Data unless providing a copy would adversely affect the rights and freedoms of others.

You can also request information about the different categories and purposes of data processing; recipients or categories of recipients who receive your Personal Data, details on how long your Personal Data is stored for, information on your Personal Data’s source and whether the Data Controller uses automated decision-making.

You also have “Data Portability” rights which includes the right to request a copy of your Personal Data be sent to you or transmitted to another Data Controller.

Correction requests

You are entitled to request that we correct or complete your inaccurate or incomplete Personal Data without undue delay and we will update the information and erase or correct any inaccuracies as required.

Erasure requests

You can exercise your “right to be forgotten”, and you can request we erase your Personal Data. Once receiving a request, we will erase the Personal Data without delay.


Responding to Your Requests

Upon receiving a request from you concerning your Personal Data, we will respond within two weeks of receiving the request by email (unless you request a response in an alternative format).

If we are unable to immediately comply with your request we will inform you within our response stating whether we need to extend our response time (for up to a maximum of two months), along with an explanation for the delay.

If we do not take any action within two weeks after receiving your request, you are entitled to request an explanation from us as to why no action was taken and you may make a complaint to the ICO: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow Cheshire SK9 5AF (Tel: 0303 123 1113) (email. casework@ico.org.uk)


 Changes to our Data Protection Policy

We keep our privacy policy under regular review and reserve the right to amend and update the policy as required. Where appropriate, we will notify you of those changes by mail, email and/or by placing an updated version of the policy on our website.