1. GLOSSARY OF TERMS
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information – e.g. emails and telephone numbers
- National Insurance Number
- Employment history
- Employee number
- Payroll and accounting data
- Personal tax records
Sensitive personal data
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Biometric data (e.g. photo in an electronic passport)
For general data protection regulation purposes, the Data Controller is the person or organisation who decides the purposes for which and the way in which any personal data is processed.
In this instance the data controller is Sixstar Limited.
A Data Processor is a person or organisation which processes personal data for the controller.
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
Business to Business
A transaction between two business such as Sixstar Limited and a PLC, LTD or Limited Company; an LLP incorporated partnership; incorporated trust or foundation, local authority or government institution.
Business to Consumer
A transaction between a business such as Sixstar Limited and an individual such as a private client, sole trader or an unincorporated partnership, trust or foundation.
2. INFORMATION WE COLLECT ABOUT YOU AND HOW
Sixstar Limited, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the services as defined in our Engagement Letter and any supporting schedules and for other related purposes including:
- Updating and enhancing client records
- Analysis for management purposes
- Carrying out credit checks in relation to you
- Statutory returns
- Legal and regulatory compliance
- Crime prevention
When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.
We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
4. IP ADDRESSES
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. This does not give Sixstar Limited access to any personal identifiable information and we do not seek such information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
5. HOW WE USE THE INFORMATION ABOUT YOU AND WHY
At Sixstar Limited we take your privacy seriously and will only use your personal information to provide the services you have requested from us, detailed in your Engagement Letter and any supporting Schedules and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
For Business to Business clients and contacts our lawful reason for processing your personal information will be ‘legitimate interests’. Under ‘legitimate interests’ we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.
For Business to Consumer clients and contacts our lawful reason for processing your personal information will be ‘A contract with the individual’ e.g. to supply services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract.
We may receive personal data from you for the purposes of our money laundering checks, e.g. a copies of your passport, driving licence and/or utility bill. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the services and we have contracts in place that require them to keep your information secure and not to use it for their own direct marketing purposes.
We collect information on our website to process your enquiry, give advice and improve our services. If you agree we will also use this information to share updates with you about our services which we believe may be of interest to you.
We will not share your information for marketing purposes.
By submitting your personal data, you’re agreeing to us transferring, storing and processing your data. As part of the services offered to you the information which you give to us will not be transferred to countries outside the European Economic Area(‘EEA’).
7. SECURITY PRECAUTIONS IN PLACE ABOUT DATA COLLECTED
When you give us personal information via our website, we take steps to make sure that it’s treated securely. Any sensitive information is encrypted and protected with Secure Sockets Layer (SSL). When you are on a secure page, a lock icon will appear in your web browser.
Email can’t be guaranteed to be 100% secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.
We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point:
- by using the unsubscribe link in any marketing email we have sent you or
- by asking us to stop contacting you for marketing purposes.
10. HOW LONG WILL WE HOLD YOUR DATA FOR?
Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.
Marketing: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
11. ACCESS TO YOUR INFORMATION AND CORRECTION
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please contact us. We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
12. OBJECTIONS TO PROCESSING OF PERSONAL DATA
It is your right to lodge an objection to the processing of your personal data if you feel there are ‘grounds relating to your particular situation’. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
13. DATA PORTABILITY
It is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
- the processing is based on consent or on a contract, and
- the processing is carried out by automated means.
14. YOUR RIGHT TO BE FORGOTTEN
Should you wish us to completely delete all information that we hold about you please contact us.
15. OTHER WEBSITES
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office.
18. HOW TO CONTACT US
Version 1.0 | Last updated: 9 May 2018