With a change in Data Protection legislation UK Fingerprints (UKF) must ensure that the business responsibility for all personal data held by the organisation is maintained in a safe and secure manner. The business must be able to demonstrate compliance with accountability in ensuring best practice.
This means that any personal data held by the business must be processed lawfully, fairly and in a transparent manner. It must only be collected for a specified, explicit and legitimate purposes. It must be adequate, relevant and limited to what is necessary and where necessary, kept up to date. Data can only be retained for as long as required and must be processed in an appropriate manner to maintain security.
UKF hold a record of client’s personal data, which include names, addresses, email address and telephone numbers for the sole purpose of communication of UK Fingerprint’s business with its client’s and service providers. The data is not shared with any other third party, (see below).
This Procedure will identify the areas of risk to the business and the manner in which the business will minimise or seek to eliminate those risks. As a business our risks are limited to three main areas:
- Client Personal Data (Names, Postal Addresses, Telephone Numbers and Email Addresses)
- Service Providers Personal Data
- Client & Service Providers Financial Data
These categories and the business’s actions in respect of each are dealt with below.
NB: SME’s with fewer than 250 employees (as in the case of UKF) have limited obligations under the Regulations.
For the purpose of this policy, “record” shall be interpreted to mean: “any papers, files, books, photographs, tapes, films, recordings, or other documentary materials, or any copies thereof, regardless of physical form or characteristics, made, produced, executed, or received by UK Fingerprints in connection with the transaction of UKF’s business.
The term “electronic record” means any record that is created, received, maintained or stored on a computer or other similar device. Examples include, but are not limited to:
- Electronic mail (e-mail)
- Word processing documents and spreadsheets
The term “data controller” means a person who (alone or jointly or on common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed.
The term “data processor”, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller
The term “processing” in relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:
- Organisation, adaptation or alteration of the information or data
- Retrieval, consultation or use of the information or data
- Disclosure of the information or data by transmission, dissemination, or otherwise making available, or data controllers and data processors 20140506 Version: 1.0.5d alignment, combination, blocking, erasure or destruction of the information or data
The term “child” is defined in the GDPR Regulations as someone under the age of 16. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, title, date of birth and gender. Contact Data includes billing address, email address, telephone numbers and emergency contact telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, cookies, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Usage Data includes information about how you use our website, products and services.
It should be noted that UKF operate as a Fingerprinting Agency not a Fingerprint Processing Agency. We will take your fingerprints on the appropriate Fingerprint Form, as requested by you, and then hand the prints back to you to be processed by yourself.
THE DATA WE COLLECT ABOUT YOU
The Policy of UKF is to ensure that any personal data held by the business will be:
- processed lawfully, fairly and in a transparent manner
- collected for a specified, explicit and legitimate purposes
- adequate, relevant, limited to what is necessary, accurate and kept up to date
- retained for as long as necessary
- processed in an appropriate manner to maintain security
Therefore we will:
- Not pass personal data to third parties other than our Business Service Providers
- Not forward fingerprint cards for clients
- Not retain a copy of the client’s fingerprint card
- Conduct regular checks on data security
- Delete data automatically after three calendar months or less unless the data is being held for repeat clients such as corporates and service providers
- Require our Data Protection Officer will carry out a regular data review to ensure compliance of GDPR
Client Personal Data
Client Data is held by the Business Development Manager who acts as our Data Protection Officer, and the data will be in either electronic or paper format.
Clients currently supply their contact data when applying to use our services which they supply either through email or telephonic communication.
Client data is held on a personal computer at the business premises, secured by way of password and anti-virus computer protection.
Email circulations are further protected by use of the ‘bcc – blind copy’ system.
Clients must provide an authority for the business to hold their personal data and in turn UKF will undertake to use that data SOLELY for contact on matters of its business and administration.
Client Data will be subject to destruction, electronically or by shredding with an Approved Contractor, upon the termination of the client’s business with UKF.
Service Providers Personal Data
A Service Provider is a business or individual who provides a service to assist with the administration or management of the business. They will include, but not be limited to, stationer’s, shredding companies, courier service providers, IT Consultants and maintenance providers of our computer services, equipment providers and similar sub-contractors used from time to time by the business. Their personal data will be treated in the same as that of our clients unless it is necessary to retain their data for continuity of the service on an ongoing basis.
Client & Service Providers Financial Data
All financial matters of the business are dealt with by the nominated person. The data is both paper and computer data based. All the relevant paper documents and computer-based date are kept at the business administration address and protected as above. Paper documents are held in a secure area whilst the computer data is held on the post holders’ personal computer, protected by password and anti-virus computer protection. The documentation is subject to an annual audit by an independent third party registered practitioner. All information is subject to HRMC rules and is held for a six-year period. Information outside this period will be subject of destruction by shredding, with an Approved Service Provider.
UKF respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you conduct business with us and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format, so you can click through to the specific areas set out. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
This privacy notice aims to give you information on how UKF collects and processes your personal data
UKF is the controller and responsible for your personal data (referred to as “UK Fingerprints”, “UKF”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer on: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Please see ‘Your Legal Rights’ below.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we have your consent.
- Where it is necessary for our legitimate interests (or those of a third party e.g. our bankers, accountants) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation (e.g. HMRC).
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data for the purposes set out in the table under How We Use Your Personal Data.
We require and expect all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. However, we are a small business and are unable to dictate to organisations such as Microsoft, Google, the USA Government’s Federal Bureau of Investigation (FBI). The latter for example processes the USA Identity History Summary Checks (aka criminal record checks) which in some instances we undertake electronically. These submissions are through the FBI Channeler Accredited Partners Scheme or via the USA Financial Regulatory Authority (FINRA) which is Accredited to the USA Government. For more clarity we suggest you visit their websites to examine their Privacy Statements.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, Certified Fingerprint Officers and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We also keep this basic information about our customers for up to seven years following your most recent purchase of a service from us, to enable us to deal efficiently with any after-sales queries that you may have. We keep customer profile information that you have indicated you are happy for us to have to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data, or until a maximum of seven years. We have implemented processes to ensure data is securely destroyed or anonymised once these retention periods are reached.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, namely:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Right to opt-out of automated profiling of your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We will acknowledge receipt of your request and try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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
Performance of Contract 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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to e.g. tax collection.
Consent means you have explicitly given us permission to process your personal data. In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the UK or EU who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EU who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
MARKETING – GENERAL
- We do not engage in activity involving the selling of your personal data to any third party.
- We do not engage in third party marketing.