Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is provided to you by Exchange IT Solutions Limited (Exchange IT) which is the data controller for your data.
What data does Exchange IT process?
All of the following where necessary to perform tasks:
- Names, titles, and aliases
- Contact details such as telephone numbers, addresses, and email addresses.
- In some cases logins and passwords to software and websites.
How do we process your personal data?
The data controller will comply with its legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
How do we use your data?
We use your personal data for some or all of the following purposes:
- To enable your queries and issues to be answered and kept for historical analysis
- To enable us to contact you in relation to the contractual services provided
- To enable Invoices and/or purchase orders to be raised
- To enable us to alert you in relation to virus detection
- To enable us to provide ongoing licence and contract renewal support
What is the legal basis for processing your personal data?
Most of our data is processed on the basis of a contract to provide or purchase goods and services. Where we are contacted by phone or email the legal basis is that of consent. We will not use this data for purposes other than to provide answers to queries or generate quotations for work.
Where your information is to be used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data:
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks according to a contract with you or where you first give us your prior consent.
Our accountants will have access to your data in the performance of their auditing duties for Exchange IT however it will be transferred securely to them and treated securely by them.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you:
- At any point you can contact us to request the information we hold on you as well as why we have this information, who has access to the information and from where we obtained the information. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you:
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased:
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data:
- You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data.
- Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability:
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought:
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
Transfer of Data Abroad
Any electronic personal data transferred to countries or territories outside the EEA will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. This would only be for the purposes of data backup. The provider would have no access to or use of your data.
If we wish to use your personal data for a new purpose, not covered by this 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. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice We keep this Privacy Notice under regular review and we will place any updates on this web page This Notice was last updated in May 2018.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller,
Exchange IT Solutions Limited
2 Queen’s Road
Phone: 028 9204 2164
You can contact the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.