Data Protection – Privacy Notice
Outsourced Procurement is committed to protecting the privacy of individuals in compliance with the General Data Protection Regulations (25.05.2018) and UK Data Protection legislation. This policy explains how and why we use personal data, the conditions under which we may disclose it to others and how we keep it secure. This applies to our website and other services provided by us, and all communications with individuals through written or oral means, such as email or telephone. We may change this Privacy Notice from time to time so please check this page occasionally to ensure that you are happy with any changes. By using our website, customer portal and communicating with us by email you are agreeing to be bound by this policy. The terms within this Privacy Notice represents your “right to be informed” under the General Data Protection Regulations (GDPR).
1. About Us
Outsourced Procurement is a trading name of Outsourced Utilities Ltd, registered in England and Wales (Company No. 09190396) with its office at Grove House, Liverpool Road, Backford, Chester CH1 6PF. We are listed on the Information Commissioner’s register of data controllers under number: ZA086104. Outsourced Utilities is the ‘data controller’ for the purpose of data protection law. As the ‘data controller’ we are responsible for deciding how we hold and use personal data.
2. What Information We Collect and Why
We collect different types of information through our business operation. This information relates to our employees, customers, suppliers, service providers, partners and third parties. The information collected may include both personal and sensitive data which could but is not limited to your name, postal address, email address, telephone number and bank details. Technical and usage data such as internet protocol (IP) address and browser data will also be collected by your use of our website.
3. How Your Personal Data Is Collected
We use different methods to collect data including through: Direct interactions. You may give us your identity, contact and financial data by filling in forms or corresponding with us. This includes data you provide when you:
– Request our services
– Complete a form on our website
– Subscribe to our services or publications or request marketing
– Give us some feedback
4. How We Use Your Information
We use the personal data that we collect in a variety of ways in operating our business but will only ever use your personal data to the extent necessary to
– Perform a contract with you;
– Comply with a legal duty;
– Undertake our own legitimate business interests provided your rights don’t override these.
Information will only be used for the purpose it was collected. We may process your personal data for more than one of the lawful reasons stated above depending on the specific purpose for which we are using your data. Legitimate interest means the interest of 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 and your rights before we process your personal data for our legitimate business interests. This includes arranging at your request your facilities. We will disclose information to third parties to arrange as requested your facilities; we limit the information provided to that which is reasonably necessary for them to perform their functions and respond to our instructions. Our relationship with them requires that they maintain confidentiality of such information and comply with GDPR and data legislation. We will never share your personal data with a third party who might use it for their own purposes. Where you supply goods or services to us your personal data will be used arising from any agreements entered into with Outsourced Utilities and to carry out our legal obligations. Generally, we do not rely on consent as a legal basis for processing your personal data but in the event that Outsourced Utilities uses your personal data for any direct marketing activities this will only be done with your consent, asking for it as appropriate. You have the right to withdraw this consent at any time and can do so by contacting the nominated Data Protection Person as detailed below.
5. Security of Your Information
Keeping your data safe is of paramount importance to us and we follow generally accepted industry standards to protect the information submitted to us. We have in place a variety of reasonable and appropriate technical and organisational measures to ensure that it is protected from accidental loss, unauthorised access, use or disclosure of it. This includes undertaking any necessary identity checks that might be appropriate before your data is disclosed. In the event of any suspected data security breach this will be immediately investigated and rectified. We will notify you and the Information Commissioner’s Office (ICO) of a suspected breach where we are legally required to do so.
6. Data Sharing
Outsourced Utilities has legal obligations to share personal data with third parties such as HMRC where there are legitimate interests or contractual reasons to do so. When it is necessary to share your data with another organisation who provide a service to us such as suppliers and banking services they are required by law to take reasonable and appropriate steps to ensure that your personal and sensitive data is secure. We only permit our third party providers to process your personal data for specified purposes and in accordance with our instructions. We will at all times limit access to your personal data on a strict business need to know basis. We will never share your personal or sensitive data with a third party who might use it for their own purposes. We will never sell your data. Your information is not shared outside the European Economic Area (EEA).
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purpose of satisfying any legal, accounting or reporting requirements. After the service provision has ended necessary data will be archived for a period of 6 years to comply with legal requirements. Where there is no legal or regulatory requirement your information will be retained for legitimate business purposes only and deleted after a period of two years. Data retention will be reviewed annually, and data will be kept for no longer than necessary.
8. Your Rights
Under data protection law you have the right to be informed about the processing of your personal data. Also, you have the right to ask to see the information we hold about you and be able to amend it if the information is inaccurate or incomplete. You have the right to request erasure, but this is not an automatic right and only applies where there is no lawful reason for us to continue to process the data. Under certain circumstances you may also have the right to object or restrict processing and transfer your personal data. If you want to exercise any of your rights’, please contact out Data Protection Person named below. You also have the right to object to automated decision making and profiling where decisions are made solely without any human intervention. Outsourced Utilities does not use any personal data in this way.
9. Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. In the event that your personal information changes please notify us of any relevant changes by contacting Outsourced Utilities nominated Data Protection Person as below.
10. Subject Access Request
If you make a request to access your personal data, this is known as a Subject Access Request (SAR). A request can be made verbally or in writing, but it must be specific and made for data protection purposes. This will be dealt with without undue delay and at the latest within one month. Provided the request is reasonable no fee will be charged. We take all necessary steps to ensure that personal information is not disclosed to any person who has no right to receive it. If you make a SAR, we will confirm your identity and ensure your right to access the information or to exercise any of your other rights.
11. Nominated Data Protection Person
Outsourced Utilities Managing Director is the nominated and responsible person for data protection. Any queries or requests for information should be referred through the HR Department at the organisation’s address or email the designated data protection address at email@example.com.
You have the right at any time to make a complaint to the ICO, the UK regulatory for data protection. You can find out more information on the ICO website https://ico.org.uk/concerns. The ICO’s contact details are as follows: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone number: 0303 123 1113 or 01625 545 745
13. Last Update
This policy was last updated on 20th May 2018.