1
Westcliff Solutions Limited
Data Protection and Priv
acy
P
olicy
1
st
May 2019
2
Westcliff Solutions
Data Protection Policy
1.
Introduction
This Policy sets out the obligations of
Westcliff Solutions Limited
, a company registered
in
England
under number
7470952
,
whose
registered office is at
87 North Road, Poole, BH14 0LT
(“the
Company”) regarding data protection and the rights of
customers,
suppliers
, employees, sub
-
contractors
and their contacts
(“data subjects”) in respect of th
eir personal data under EU Regulation
2016/679 General Data Protection Regulation (“GDPR”).
The GDPR
defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an
identifiable natural person is o
ne who can be identified, directly or indirectly, in particular by reference to an identifier such a
s a name,
an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiologi
cal, genetic,
mental,
economic, cultural, or social identity of that natural person.
This Policy sets the Company’s oblig
ations regarding the collection, processing, transfer, storage, and disposal of personal data. The
procedures and principles set out herein must be followed
at all times by the Company, its employees, agents, contractors, or other
parties working on behalf
of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on t
he correct,
la
wful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all
individuals with whom it deals.
2.
The Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following princi
ples with which any party handling
personal data must comply. All personal data must be:
2.1
Processed l
awfully, fairly, and in a transparent manner in relation to the data subject.
2.2
Collected for specified, explicit, and legitimate purposes and not further pro
cessed in a manner that is incompatible with
those purposes. Further processing for archiving purpos
es in the public interest, scientific or historical research purposes or
statistical purposes shall not be considered to be incompatible with the initial pu
rposes.
2.3
Adequate, relevant, and limited to what is necessary in relation to the purposes for which i
t is processed.
2.4
Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is
inaccurate, having
regard to the purposes for which it is processed, is erased, or rectified without delay.
2.5
Kept in a f
orm which permits identification of data subjects for no longer than is necessary for the purposes for which the
personal data is processed. Personal data m
ay be stored for longer periods insofar as the personal data will be processed
solely for archiving
purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject
to implementation of the appropriate technical
and organisational measures required by the GDPR in order to safeguard the
rights and freedoms of t
he data subject.
2.6
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or
unlawful process
ing and against accidental loss, destruction, or damage, using appropriate technical or organisation
al
measures.
3.
The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indic
ated for further details):
3.1
The right to be informed (Part 12).
3.2
The right of access (Part 13);
3.3
The ri
ght to rectification (Part 14);
3.4
The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
3.5
The right to restrict processing (Part 16);
3.6
The
right to object (Part 1
7); and
4.
Lawful, Fair, and Transparent Data Processing
4.1
The GDPR seeks to ensur
e that personal data is processed lawfully, fairly, and transparently, without adversely affecting the
rights of the data subject. The GDPR states that proc
essing of personal data shall be lawful if at least one of the following
3
applies:
4.1.1
The data subject h
as given consent to the processing of their personal data for one or more specific purposes;
4.1.2
The processing is necessary for the performance of a contract t
o which the data subject is a party, or in order to
take steps at the request of the data subject pr
ior to entering into a contract with them;
4.1.3
The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4.1.4
The p
rocessing is necessary to protect the vital interests of the data subject or of another natural pers
on;
4.1.5
The processing is necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the data
controller; or
4.1.6
The processing is necessary for the purposes of the legitimate interests pursued by
the data controller or by a third
party, except where such interests are overridden by the fundamental rights and freedoms of the data subject
which require
protection of personal data, in particular where the data subject is a child.
5.
Specified, Explicit,
and Legitimate Purposes
5.1
The Company collects and processes the personal data set out in Part
18
of this Policy. This includes:
5.1.1
Personal data collected dire
ctly from data subjects
5.2
The Company only collects, processes, and holds personal data for the specif
ic purposes set out in Part
18
of this Policy (or
for other purposes expressly permitted by the GDPR).
5.3
Data subjects are kept informed at all times of the p
urpose or purposes for which the Company uses their personal data.
Please refer to Part 12 for more
information on keeping data subjects informed.
6.
Adequate, Relevant, and Limited Data Processing
The Company will only collect and process personal data for
and to the extent necessary for the specific purpose or purposes of which
data subjects have been in
formed (or will be informed) as under Part 5, above, and as set out in Part
18
, below.
7.
Accuracy of Data and Keeping Data Up
-
to
-
Date
7.1
The Company shall ensur
e that all personal data collected, processed, and held by it is kept accurate and up
-
to
-
date. This
includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14,
below.
7.2
The accuracy of personal
data shall be checked when it is collected and at regular
intervals thereafter. If any personal dat
a is
found to be inaccurate or out
-
of
-
date, all reasonable steps will be taken without delay to amend or erase that data, as
appropriate.
8.
Data Retention
8.1
Th
e Company shall not keep personal data for any longer than is necessary in light of the purpose or p
urposes for which that
personal data was originally collected, held, and processed.
8.2
When personal data is no longer required, all reasonable steps will be t
aken to erase or otherwise dispose of it without
delay.
8.3
For full details of the Company’s approach t
o data retention, including retention periods for specific personal data types held
by the Company, please refer to our Data Retention Policy.
9.
Secure Proce
ssing
The Company shall ensure that all personal data collected, held, and processed is kept secure
and protected against unauthorised or
unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisa
tional measures
which shall be taken are provided in Parts
19
to 2
4
of this Policy.
4
10.
Accountability
and Record
-
Keeping
10.1
The Company’s Data Protection Officer is
Luke Wilson
,
email
luke.wilson@westcl
iffsolution.co.uk
, telephone 020 8133 3501
and 07767 201078
.
10.2
The Data Protection Officer shall be r
esponsible for overseeing the implementation of this Policy and for monitoring
compliance with this Policy, the Company’s other data protection
-
related poli
cies, and with the GDPR and other applicable
data protection legislation.
10.3
The Company shall keep wri
tten internal records of all personal data collection, holding, and processing, which shall
incorporate the following information:
10.3.1
The name and details of t
he Company, its Data Protection Officer, and any applicable third
-
party data processors;
10.3.2
The purpose
s for which the Company collects, holds, and processes personal data;
10.3.3
Details of the categories of personal data collected, held, and processed by the Compa
ny, and the categories of
data subject to which that personal data relates;
10.3.4
Details of any transfers
of personal data to non
-
EEA countries including all mechanisms and security safeguards;
10.3.5
Details of how long personal data will be retained by the Company (
please refer to the Company’s Data Retention
Policy); and
10.3.6
Detailed descriptions of all technical and
organisational measures taken by the Company to ensure the security of
personal data.
11.
Data Protection Impact Assessments
11.1
The Company shall carry out Data
Protection Impact Assessments for any and all new projects and/or new uses of personal
data.
11.2
Data Pr
otection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
11.2.1
The type(s) of personal data that will be coll
ected, held, and processed;
11.2.2
The purpose(s) for which personal data is to be used;
11.2.3
The Company’s obje
ctives;
11.2.4
How personal data is to be used;
11.2.5
The parties (internal and/or external) who are to be consulted;
11.2.6
The necessity and proportionality of the data proce
ssing with respect to the purpose(s) for which it is being
processed;
11.2.7
Risks posed to data subjects;
11.2.8
Risks posed both within and to the Company; and
11.2.9
Proposed measures to minimise and handle identified risks.
12.
Keeping Data Subjects Informed
12.1
The Company shall
provide the information set out in Part 12.2 to every data subject:
12.1.1
Where personal data is collecte
d directly from data subjects, those data subjects will be informed of its purpose at
the time of collection; and
12.1.2
Where personal data is obtained from a thi
rd party, the relevant data subjects will be informed of its purpose:
a)
if the personal data is used t
o communicate with the data subject, when the first communication is made; or
b)
if the personal data is to be transferred to another party, before that transf
er is made; or
c)
as soon as reasonably possible and in any event not more than one month after the per
sonal data is obtained.
12.2
The following information shall be provided:
12.2.1
Details of the Company including, but not limited to, the identity of its Data Protecti
on Officer;
5
12.2.2
The purpose(s) for which the personal data is being collected and will be processed (as
detailed in Part
18
of this
Policy) and the legal basis justifying that collection and processing;
12.2.3
Where applicable, the legitimate interests upon which the
Company is justifying its collection and processing of the
personal data;
12.2.4
Where the personal data i
s not obtained directly from the data subject, the categories of personal data collected
and processed;
12.2.5
Where the personal data is to be transferred to one
or more third parties, details of those parties;
12.2.6
Where the personal data is to be transferred to a t
hird party that is located outside of the European Economic Area
(the “EEA”), details of that transfer, including but not limited to the safeguards in place
(see Part 2
5
of this Policy
for further details);
12.2.7
Details of data retention;
12.2.8
Details of the data su
bject’s rights under the GDPR;
12.2.9
Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at
any time;
12.2.10
Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supe
rvisory
authority” under the GDPR);
12.2.11
Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and
process
ing of the personal data and details of any consequences of failing to provide it; and
12.2.12
Details of an
y automated decision
-
making or profiling that will take place using the personal data, including
information on how decisions will be made, the significance
of those decisions, and any consequences.
13.
Data Subject Access
13.1
Data subjects may make subject acces
s requests (“SARs”) at any time to find out more about the personal data which the
Company holds about them, what it is doing with that personal data, and w
hy.
13.2
Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Req
uest Form, or other
written communication. SARs should be addressed to the Company’s Data Protection Officer at
87 North Road, Poole BH14
0LT
.
13.3
Responses to
SARs shall normally be made within one month of receipt, however this may be extended by up to two m
onths
if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be
informed.
13.4
All SARs received sh
all be handled by the Company’s Data Protection Officer.
13.5
The Company does not charge a fee for the h
andling of normal SARs. The Company reserves the right to charge reasonable
fees for additional copies of information that has already been supplied to a da
ta subject, and for requests that are
manifestly unfounded or excessive, particularly where such req
uests are repetitive.
14.
Rectification of Personal Data
14.1
Data subjects have the right to require the Company to rectify any of their personal data that is inac
curate or incomplete.
14.2
The Company shall rectify the personal data in question, and inform the data s
ubject of that rectification, within one month
of the data subject informing the Company of the issue. The period can be extended by up to two months in the
case of
complex requests. If such additional time is required, the data subject shall be informed.
14.3
In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any
rectification that must be made to
that personal data.
15.
Erasure of Personal Data
15.1
Data subjects have the right to request that the Compa
ny erases the personal data it holds about them in the following
circumstances:
6
15.1.1
It is no longer necessary for the Company to hold that personal data with re
spect to the purpose(s) for which it was
originally collected or processed;
15.1.2
The data subject wishes
to withdraw their consent to the Company holding and processing their personal data;
15.1.3
The data subject objects to the Company holding and processing their pe
rsonal data (and there is no overriding
legitimate interest to allow the Company to continue doing s
o) (see Part 18 of this Policy for further details
concerning the right to object);
15.1.4
The personal data has been processed unlawfully;
15.1.5
The personal data needs
to be erased in order for the Company to comply with a particular legal obligation
.
15.2
Unless the Comp
any has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied
with, and the data subject informed of the erasure,
within one month of receipt of the data subject’s request. The period can
be extended by up to two m
onths in the case of complex requests. If such additional time is required, the data subject shall
be informed.
15.3
In the event that any personal data that is
to be erased in response to a data subject’s request has been disclosed to third
parties, those part
ies shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do
so).
16.
Restriction of Personal Data Processing
16.1
D
ata subjects may request that the Company ceases processing the personal data it holds about them. I
f a data subject
makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is
necessary to
ensure that the personal data in question is not processed further.
16.2
In the event that any affected p
ersonal data has been disclosed to third parties, those parties shall be informed of the
applicable restrictions on processing it (unless it is impossible o
r would require disproportionate effort to do so).
17.
Objections to Personal Data Processing
17.1
Data subj
ects have the right to object to the Company processing their personal data based on legitimate interests, direct
marketing (including profiling.
17.2
Where a da
ta subject objects to the Company processing their personal data based on its legitimate interests,
the Company
shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such
processing override the da
ta subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of
legal claims.
17.3
Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company
shall cease such proces
sing immediately.
7
18.
Personal Data Collected, Held, and Processed
The following personal data is coll
ected, held, and processed by the Company (for details of data retention, please refer to the
Company’s Data Retention Policy):
Data Ref.
Type of Data
Purp
ose of Data
Customers
Company names, contact names, postal
addresses, email addresses, telephone
nu
mbers, Skype IDs
.
Used to contact customers in relation to the
development of software and
other related
services.
Suppliers
Company names, contact names,
postal
addresses, email addresses, telephone
numbers, Skype IDs, bank account numbers
and sort codes
.
Used to contact suppliers in connection with
provided services. B
ank details are retained online
for payment
processing
.
Employees
Postal addresses, emai
l addresses,
telephone numbers, Skype IDs, bank
account numbers and sort codes.
Used to contact and
make payment to employees.
Bank details are retained online for payment
processing
.
Sub
-
contractors
Postal addresses, email addresses,
telephone numbers, S
kype IDs, bank
account numbers and sort codes.
Used to contact and make payment to sub
-
contractors.
Bank details are retained online
for
payment processing
.
19.
Data Security
-
Transferring Personal Data and Communications
The Company shall ensure that the
following measures are taken with respect to all communications and other transfers involving
person
al data:
19.1
All emails containing personal data must be encrypted
.
19.2
All emails containing personal data must be marked “confidential”;
19.3
Personal data may be tran
smitted over secure networks only; transmission over unsecured networks is not permitted in any
circ
umstances;
19.4
Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
19.5
Personal data contai
ned in the body of an email, whether sent or received, should be copied from the body of that email
and
stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted
.
19.6
Where personal data is to be sent
by facsimile transmission the recipient should be informed in advance of the transmission
and should
be waiting by the fax machine to receive the data;
19.7
Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient
and
19.8
All personal data to be transferred physically, whether in hardcopy form or on removable electro
nic media shall be
transferred in a suitable container marked “confidential”.
20.
Data Security
-
Storage
The Company shall ensure that the following measures
are taken with respect to the storage of personal data:
20.1
All electronic copies of personal data shoul
d be stored securely using passwords
.
20.2
All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored
securely in a locked box, drawer, cabinet, or similar;
20.3
All personal data stored electronically shou
ld be backed up
weekly
with
backups
stored onsite
and
offsite. All backups should
be encrypted
.
20.4
No personal data should be transferred to any device persona
lly belonging to an employee and personal data may only be
transferred to devices belonging to agent
s, contractors, or other parties working on behalf of the Company where the party
in question has agreed to comply fully with the letter and spirit of this
Policy and of the GDPR (which may include
demonstrating to the Company that all suitable technical a
nd organisational measures have been taken).
8
21.
Data Security
-
Disposal
When any personal data is to be erased or otherwise disposed of for any reason (inclu
ding where copies have been made and are no
longer needed), it should be securely deleted and dispos
ed of. For further information on the deletion and disposal of personal data,
please refer to the Company’s Data Retention Policy.
22.
Data Security
-
Use of P
ersonal Data
The Company shall ensure that the following measures are taken with respect to the use
of personal data:
22.1
No personal data may be shared informally and if an employee, agent, sub
-
contractor, or other party working on behalf of
the Company requi
res access to any personal data that they do not already have access to, such access should be forma
lly
requested from
the Company’s Data Protection Officer
.
22.2
No personal data may be transferred to any employees, agents, contractors, or other parties, wheth
er such parties are
working on behalf of the Company or not, without the authorisation of
the Compan
y’s Data Protection Officer
.
22.3
Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised
employees, ag
ents, sub
-
contractors, or other parties at any time;
22.4
If personal data is being viewed on a computer
screen and the computer in question is to be left unattended for any period
of time, the user must lock the computer and screen before leaving it; and
22.5
Where
personal data held by the Company is used for marketing purposes, it shall be the responsibility of
the Company’s
Data Protection Officer
to ensure that the appropriate consent is obtained and that no data subjects have opted out,
whether directly or via
a third
-
party service such as the TPS.
23.
Data Security
-
IT Security
The Company shall ensure that th
e following measures are taken with respect to IT and information security:
23.1
All passwords used to protect personal data should be changed regularly and shou
ld not use words or phrases that can be
easily guessed or otherwise compromised. All passwords must
contain a combination of uppercase and lowercase letters,
numbers, and symbols.
23.2
Under no circumstances should any passwords be written down or shared betwee
n any employees, agents, contractors, or
other parties working on behalf of the Company, irrespectiv
e of seniority or department. If a password is forgotten, it must
be reset using the applicable method. IT staff do not have access to passwords;
23.3
All softwa
re (including, but not limited to, applications and operating systems) shall be kept up
-
to
-
date. The
Company’s IT
staff shall be responsible for installing any and all security
-
related as soon as reasonably and practically possible, unless there
are valid
technical reasons not to do so; and
23.4
No software may be installed on any Company
-
owned computer or de
vice without the prior approval of the
Company’s Data
Protection Officer
.
24.
Organisational Measures
The Company shall ensure that the following measures are
taken with respect to the collection, holding, and processing of personal
data:
24.1
All employees, agent
s, contractors, or other parties working on behalf of the Company shall be made fully aware of both
their individual responsibilities and the Company’s resp
onsibilities under the GDPR and under this Policy, and shall be
provided with a copy of this Policy;
24.2
Only employees, agents, sub
-
contractors, or other parties working on behalf of the Company that need access to, and use of,
personal data in order to carry
out their assigned duties correctly shall have access to personal data held by the Company;
24.3
All emp
loyees, agents, contractors, or other parties working on behalf of the Company handling personal data will be
appropriately trained to do so;
24.4
All employees,
agents, contractors, or other parties working on behalf of the Company handling personal data will
be
appropriately supervised;
9
24.5
All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be
required
and encouraged to exercise care, caution, and discretion when discussing work
-
related matters that r
elate to
personal data, whether in the workplace or otherwise;
24.6
Methods of collecting, holding, and processing personal data shall be regularly evaluated and
reviewed;
24.7
All personal data held by the Company shall be reviewed periodically, as set out in the C
ompany’s Data Retention Policy;
24.8
The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling
personal
data shall be regularly evaluated and reviewed;
24.9
All employees, agents, contractors, or other partie
s working on behalf of the Company handling personal data will be bound
to do so in accordance with the principles of the GDPR and this Policy by contract;
24.10
All agents, contractors, or other parties working on behalf of the Company handling personal data mu
st ensure that any and
all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant
employee
s of the Company arising out of this Policy and the GDPR; and
24.11
Where any agent, contractor or other p
arty working on behalf of the Company handling personal data fails in their
obligations under this Policy that party shall indemnify and hold harmless the C
ompany against any costs, liability, damages,
loss, claims or proceedings which may arise out of tha
t failure.
25.
Transferring Personal Data to a Country Outside the EEA
25.1
The Company may from time to time transfer (‘transfer’ includes making available remotel
y) personal data to countries
outside of the EEA.
25.2
The transfer of personal data to a country outside
of the EEA shall take place only if one or more of the following applies:
25.2.1
The transfer is to a country, territory, or one or more specific sectors in that
country (or an international
organisation), that the European Commission has determined ensures an a
dequate level of protection for personal
data;
25.2.2
The transfer is to a country (or international organisation) which provides appropriate safeguards in the for
m of a
legally binding agreement between public authorities or bodies; binding corporate rules; stan
dard data protection
clauses adopted by the European Commission; compliance with an approved code of conduct approved by a
supervisory authority (e.g. the I
nformation Commissioner’s Office); certification under an approved certification
mechanism (as provi
ded for in the GDPR); contractual clauses agreed and authorised by the competent supervisory
authority; or provisions inserted into administrative arrangeme
nts between public authorities or bodies authorised
by the competent supervisory authority;
25.2.3
The tran
sfer is made with the informed consent of the relevant data subject(s);
25.2.4
The transfer is necessary for the performance of a contract between the data subject
and the Company (or for pre
-
contractual steps taken at the request of the data subject);
25.2.5
The transf
er is necessary for important public interest reasons;
25.2.6
The transfer is necessary for the conduct of legal claims;
25.2.7
The transfer is necessary to protect the v
ital interests of the data subject or other individuals where the data
subject is physically or lega
lly unable to give their consent; or
25.2.8
The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and
whi
ch is open for access by the public in general or otherwise to those who are able to show a legitima
te interest in
accessing the register.
10
26.
Data Breach Notification
26.1
All personal data breaches must be reported immediately to the Company’s Data Protection O
fficer.
26.2
If a personal data breach occurs and that breach is likely to result in a risk to the rights
and freedoms of data subjects (e.g.
financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic
damage),
the Data Protection Officer must ensure that the Information Commissioner’s Office is info
rmed of the breach without delay,
and in any event, within 72 hours after having become aware of it.
26.3
In the event that a personal data breach is likely to r
esult in a high risk to the rights and freedoms of data subjects, the Data
Protection Officer must e
nsure that all affected data subjects are informed of the breach directly and without undue delay.
26.4
Data breach notifications shall include the following inf
ormation:
26.4.1
The categories and approximate number of data subjects concerned;
26.4.2
The categories and appro
ximate number of personal data records concerned;
26.4.3
The name and contact details of the Company’s data protection officer (or other contact point where more
i
nformation can be obtained);
26.4.4
The likely consequences of the breach;
26.4.5
Details of the measures taken, o
r proposed to be taken, by the Company to address the breach including, where
appropriate, measures to mitigate its possible adverse effects.
27.
Implementatio
n of Policy
This Policy shall be deemed effective as of
01/05/201
9
. No part of this Policy shall hav
e retroactive effect and shall thus apply only to
matters occurring on or after this date.
11
Westcliff Solutions
Subject Access Request
Important Info
rmation
Westcliff Solutions Limited
collects, holds, and processes certain personal data about our
customers, suppliers, employees and sub
-
contractors
(“data subjects”). As a data subject
, you have a legal right, under EU Regulation 2016/679 General Data
Protection Regulation (“GDPR”) to find
out about our use of your personal data as follows:
•
Confirmation that your personal data is being processed by us;
•
Access to your personal data;
•
How
we use your personal data and why;
•
Details of any sharing or transf
ers of your personal data;
•
How long we hold your personal data;
•
Details of your rights under the GDPR including, but not limited to, your rights to withdraw your consent to our use of your
personal
data at any time and/or to object to our processing of it.
No fee is payable under normal circumstances. We reserve the right to charge a reasonable fee for requests that are manifestl
y unfounded,
excessive, or repetitive. Such charges will be b
ased only on the administrative cost that we will incur in order to
respond.
Please complete the required information overleaf and return it to us by email
or
by post addressed to:
Luke Wilson
Westcliff Solutions Limited
87 North Road
Poole
BH14 0LT
You
do not have to use this form and may instead write to us using the
same contact details.
After receiving your subject access request, we may contact you to request additional supporting information and/or proof of
your identity. This
helps us to safeguar
d your privacy and personal data.
We will respond to all subject ac
cess requests within one month of receipt and will aim to provide all required information to you within the
same period. If we require more information from you, or if your request is unu
sually complicated, we may require more time and will inform
you acc
ordingly.
If you are making a subject access request on someone else’s behalf, please contact
the above Data Protection Officer
before making your
request.
Data Protection Officer:
Luke
Wilson
Email:
luke.wilson@westcliffsolutions.co.uk
Telephone:
02
0 8133 3501 or 07767 201078
12
Westcliff Solutions
Subject Access Request Form
Your Details
Title:
Forename(s):
Surname:
Address:
Telephone Number:
Email Address:
Information Being Requested
Please provide specific details (along with any
relevant dates) of the information being requested and any additional information that may help
us to locate your personal data and to confirm your identity.
By completing this f
orm, you are making a subject access request under the GDPR for personal data
collected, processed, and held about you by
us that you are entitled to receive.
Declaration
By signing below, you confirm that you are the data subject named in t
his Subject Access Request Form. You warrant that you are the individual
named
and will fully indemnify
Westcliff Solutions Limited
for all losses and expenses incurred if you are not. We cannot accept requests in
respect of your personal data from anyone
else, including members of your family.
Name:
Signature:
Date:
13
Westcl
iff Solutions
Privacy Policy
B
ackground
:
Westcliff Solutions Limited
understands that your privacy is important to you and that you care about how your
personal data is used and shared online. We respect and value the privacy of everyone who visits this
website,
www.
westcliffsolutions.co.uk
(“Our Site”) and (subject to the limited exceptions in section 6, below) We do not collect
personal data about you unless you contact us (see section 5, below). Any personal data We do collect will only be
used as per
mitted by law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is
deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop
us
ing Our Site i
mmediately.
28.
Definitions and Interpretation
In this
Policy,
the following terms shall have the following meanings:
“
personal data”
means any and all data that relates to an identifiable person
who can be directly or indirectly identified fr
om that data.
In
this case, it means personal data that you give to Us via Our
Site
and
“
We/Us/Our
”
means
Westcliff Solutions Limited
, a limited company
registered in England under company number
7470952
, whose
registered address is
87 North Road, Poole,
BH14 0LT
.
29.
In
formation About Us
29.1
Our Site is owned and operated by
Westcliff Solutions Limited
, a limited company registered in
England under company number
7470952
, whose registered address is
87 North Road, Poole, BH14
0LT
.
29.2
Our VAT number is
942650816
.
29.3
Our Data Prote
ction Officer is
Luke Wilson
, and can be contacted by email at
info@westcliffsolutions.co.uk
, by telephone on
020 8133 3501
, or by post at
87
North Road, Poole.
BH14 0LT
.
30.
What Does This Policy Cover?
This Privacy Policy applies only to your
use of Our Sit
e. Our Site may contain links to other websites. Please
note that We have no control over how your data is collected, stored, or used by other websites and We
advise you to check the privacy policies of any such websites before providing any
data to them.
31.
What Data Do We Collect?
31.1
Subject to section 5
.2, We do not collect any personal data from you. We do not place cookies on your
computer or device, nor do We use any other means of data collection.
14
31.2
If you send Us an email, We may collect your
name, your em
ail address, and any other inform
ation
which you choose to give U
s.
32.
How Do We Use Your Data?
32.1
If We do collect any personal data, it will be processed and stored securely, for no longer than is
necessary in light of the reason(s) for which it
was first co
llected. We will comply with Our obligations
and safeguard your rights under the Data Protection Act 1998
and
GDPR
at all times.
32.2
As noted above, We do not generally collect any personal data. If you contact Us and We obtain your
personal detai
l
s
from your
email, We may use
them
as follows:
32.2.1
To reply to your email;
32.3
You have the right to withdraw your consent to Us using your personal data at any time, and to
request that We delete it.
32.4
We will not share any of your data with any third parties for
any purposes.
33.
How and Where Do We Store Your Data?
33.1
We only keep your personal data for as long as We need to in order to use it as described above in
section
5
, and/or for as long as We have your permission to keep it.
33.2
Your data will only be stored in the
UK.
33.3
Data se
curity is very important to Us, and to protect your data We have taken suitable measures to
safeguard and secure any data We hold about you (even if it is only your email address).
34.
How Can You Access Your Data?
You have the right to ask for a
copy of any
of your personal data held by Us (where such data is held). Please
contact Us for more details at
info@westcliffsolutions.co.uk
, or using the contact details below in section
8
.
35.
Contacting Us
If you have any questions about Our Site or this P
rivacy Policy
, please contact Us by email at
info@westcliffsolutions.co.uk
, by telephone on
020 8133 3501
, or by post at
87
North Road, Poole, BH14 0LT
.
Please ensure that your query is clear, particularly if it is a request for information about the data
We ho
ld
about
you (as under section 8
, above).
36.
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be
immediately posted on Our Site and you will be deemed to have accepted
the terms of
the Privacy Policy on
your first use of Our Site following the alterations. We recommend that you check this page regularly to keep
up
-
to
-
date.
15
This Policy has been approved and authorised by:
Name:
Luke Wilson
Position:
Managing Directo
r
Date:
01/
05/2019
Due for Review by:
01/05/2020
Signature:
D
o
cument Reviewed by LNW
0
1
/
0
5
/
201
9
.