Introduction
European Computer Support Services Limited (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
We are an IT Consultancy and Support business, with supply relationships with other cloud computing providers. It is our role to manage some of these facilities on behalf of our clients and in that process, we can act as in an advisory capacity to client data controllers. We act as the data controller for all internally stored and processed data within our business.
The following company websites and systems are within scope for this privacy policy:
www.eurocomp.co.uk
Eurocomp managed sites within Microsoft SharePoint Online
Eurocomp managed sites within Microsoft Dynamics 365
Eurocomp managed sites within Microsoft Azure
Eurocomp managed sites within Amazon Web Services
Eurocomp corporate and accounting systems
These websites are configured with the cloud providers to be UK based systems and this is checked by ourselves as far as is practicable.
It includes personal data that is collected through our websites, by telephone or by email and that is subsequently stored and processed within our own controlled and owned enterprise network or within our hosted cloud facilities.
Our registered office address is:
European Computer Support Services Ltd
Suite 207
Queens House
Queen Street
Barnstaple
EX32 8HJ
United Kingdom
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at privacy@eurocomp.co.uk.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
1. To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
3. To fulfil a contract that we have entered into with you or with the entity that you represent;
4. To ensure the security and safe operation of our websites and underlying business infrastructure, and
5. To manage any communication between you and us.
Technical information
In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
Your login information, browser type and version, time zone setting, browser plug-in types and versions;
Operating system and platform;
Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.
Our cookies policy, which can be viewed from the home page of our web sites, describes how we use cookies.
4. Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business processing, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, company-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
|
Purpose of collection |
Information category |
Data collected |
Purpose for collection |
Lawful basis for processing |
Data shared with? |
Retention period |
|
1. |
Subject matter information |
Name, |
To provide appropriate online or email information about products and services that you have requested |
Contractual fulfilment |
Internally only |
Maximum 8 years from the date that the information is collected. |
|
To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest. |
Legitimate interest |
Internally only |
||||
|
Telephone number |
Follow-up |
Legitimate interest |
Internally only |
|||
|
Personal |
General |
Consent |
Internally only |
|||
|
2. |
Transaction details |
Name, |
To process purchase transactions for products and services with customers and suppliers, and to ensure any transaction issues can be dealt with. |
Contractual |
Internally, partners |
Maximum 8 years from the date of the performance of the contract. 6 months from the date that the data subject has input personal information but has not proceeded with a transaction. 8 years for VAT records from the performance of the contract |
|
For accounting and taxation purposes |
Statutory |
Internally |
||||
|
Documentation |
Legitimate |
Internally |
||||
|
3. |
Fulfilment data |
Name, |
Access to training courses, attendance registers |
Contractual |
Internally |
Maximum 6 years from the date of the performance of the contract. |
|
Name, |
Licensing |
Contractual |
Internally and any third parties whose products or services you may have purchased from us. |
|||
|
Name, |
Actual delivery of products or services, in physical or digital form, that you may have purchased from us. |
Contractual |
Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements. |
|||
|
Technical information, as described above, plus any |
To protect our websites and infrastructure from cyber attack or other threats |
Legitimate interest |
Internally, partners, |
|||
|
4. Security |
Security information |
Names, |
To communicate with you about any issue that you raise with us or which follows from an interaction between us. |
Legitimate interest |
Internally and, as necessary, with professional advisers. |
Relevant statutes of limitation |
|
5. Communications |
Contact information |
Names, |
To reply to communications originating from outside of the business |
Legitimate interest |
Internally |
Relevant statutes of limitation. |
More information on lawful processing can be found on the ICO website.
5. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with our partners who have a need to know that information to deliver their services to you.
6. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will potentially prevent us supplying services to you.
7. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• THE RIGHT TO WITHDRAW YOUR CONSENT TO THE PROCESSING AT ANY TIME, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
8. Transfer of Data Abroad
WE DO NOT KNOWINGLY TRANSFER PERSONAL DATA OUTSIDE THE EEA.
If we are providing services utilising third party cloud providers we will ensure you are provided with access to their GDPR and privacy policy statements in order that you can assess if the service(s) meet your specific needs.
9. Automated Decision Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.
10. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy 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.
11. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
12. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our data representative at privacy@eurocomp.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 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, England.