General Privacy Policy

May 2018

Introduction

We respect your privacy and understand that privacy is important to you and that you care about how information about you is used, so this privacy notice sets out details about what data we collect and how we use it.

We hold data about you, generally so that we can perform the contract between us, we anticipate doing business together or for legal reasons.

Visitors to our website

Where we collect personal data via our website, we will be upfront about it and it will be obvious to you that you’re providing personal data and how we will be using it. A separate privacy policy is available.

People who call our office

Visitors calling to the office are either going to arrive at reception then go into the stock room or come upstairs to the office.

We have CCTV in our reception lobby which does not infringe on the public area. This is for us to identify who has arrived at our inner door. Whilst we can see images from this recording, it is overwritten every day and only the senior team have access to the information. We do not share it with anyone and the lobby has a notice that identifies that we are recording who is in there.

People arriving are identified by speaking to us through the intercom.

We have no signing in book and we keep no records of who has arrived on site, apart from CCTV.

To place an order

Orders are normally placed by phone or email and written onto a job sheet.

We collect: Name, site address, billing address, email and telephone number at this stage.

This information is passed through Sage and the paper copies stored in our locked cabinets in the office.

We may share important technical documents via Dropbox but access to each file is restricted and shared only to the client/person[s] that we know requires that information in order to fulfil the contract. We do not openly share this. Dropbox’s privacy policy can be found here

https://www.dropbox.com/en_GB/privacy

For enquiries that do not proceed, the details are kept on paper until the outcome is known and it is then shredded. Not proceeding matters are not put on Sage. For details of this please see the section under retention.

People who contact us via email

As a business, we use Outlook and our information is stored by them in accordance with their own privacy policy

https://privacy.microsoft.com/en-gb/privacystatement

In our office, our computers are password protected. Our staff have smart mobile phones and the security of these is controlled by fingerprint and or password.

Our use of social media

We use Facebook and Twitter to raise and maintain our profile. We do not target individuals or businesses. The information is stored and held in accordance with Facebook and Twitter policies. See below

https://en-gb.facebook.com/policy.php

https://twitter.com/en/privacy

People who are our customers

We hold your data on Sage for accountancy and credit control reasons for 7 financial years. This is held on our password protected computer systems.

https://www.sage.co.uk/uk/hrpayrollhero/privacy-policy

Employee data

We hold our employee’s data for the purposes of performing the employment contract and legal reasons. We have paper employee files which are kept in a locked cupboard and only accessed by authorised staff (Directors, HR personnel and accountants)

We have a separate employee privacy policy which has been given to all members of staff.

Our Suppliers

We collect Name, address, bank details, phone number, email address for remittances and payments. This information is held on Sage and paper copies are in a locked filing cabinet.

https://www.sage.co.uk/uk/hrpayrollhero/privacy-policy

Retention

Unless stated elsewhere in this document or in our terms of business we only store the data necessary to provide the services we provide to you. We will keep this data for as long as it is lawful for us to do so (this may be for as long as you are a customer or because of a legal obligation to retain the information, whichever is the longest).

For example we keep accounting information for 7 financial years and job sheets for 2 calendar years.

CCTV images are overwritten every day.

We destroy our paperwork by sending it to an authorised shredding company.

Third party processors

We use a number of third-party cloud-based services for the purposes of effectively running our business and providing our services to you. We also use a number of third-party organisations, e.g. accountants, HR support, etc.

Within the trade, we also send out to other businesses, plans, drawings and quotes to enable them to assist us in technical matters. In order for the correct identification to be recognised, we identify the address of the property at this stage. No other personal details are given.

In all cases where we are using a third-party service or company, we will only provide the minimal amount of information for the purposes of delivering the service to us and to meet our requirements.

We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with data protection, maintaining adequate security of your data and ensuring they apply adequate data protection principles to the processing of the data we supply.

Sage is only accessed by senior members of the business team.

Marketing

We don’t direct market anyone, we don’t keep data for those purposes. We do use Facebook and Yell.com for the purposes of raising our profile. When using these two applications, you will be directed to our web page. We do not collect individual data from this, and all details of our online privacy policy are given on our web page.

Your rights

Under current data protection legislation in the UK, you have rights as an individual which you can exercise in relation to the data we store and process about you. You can find more information about your rights on the Information Commissioner’s website: https://ico.org.uk/for-the-public/

Complaints

If you want to make a complaint about the way we are processing your data, you can contact us, using the contact details below. You also have the right to complain to the Information Commissioner’s Office: https://ico.org.uk/concerns/

How to withdraw consent and object to processing

Where we are processing your data and needed to ask your permission to do so, you are able to withdraw your consent at any time. If you wish to stop receiving our marketing emails you can do so, by clicking on the “unsubscribe” link at the bottom or the email. Otherwise, you can contact us, using the contact details below.

If you wish to raise concerns about the way we are processing your data or would like to raise an objection, then please email us via office@croombs.co.uk with your concerns.

Keeping your data up to date

It is important that any of your data that we process is kept up to date. We will from time to time ask you to verify your contact details but if you wish to update any information we hold about you, please contact us using the contact details below.

Erasure of your data (the “right to be forgotten”)

Under some circumstances, you may request us to delete your data from our systems. Where this is possible (e.g. we don’t have any legal purpose for continuing to process your data) we will erase it from our systems.

If you wish to exercise your right to be forgotten, please contact us via the contact details below.

Portability

Your right to portability allows you to request a machine-readable format of the data you supplied to us and associated service logs (where we store them). Please contact us, using the contact details below, if you wish to receive a CSV export of your data.

Access to your data

You have the right to ask us about what data we hold about you, how we process it and provide you with a copy of the information, free of charge and within one month of your request.

To make a request for any personal information we hold and process about you, we would prefer it if you could put it in writing or in an email to the addresses below. We will need to verify your identity before providing the information and where necessary may contact you further to ensure we understand what data you are requesting.

Disclosure of information

We do not share any personal data with any third parties unless it is lawful for us to do so, if required by law to do so or if you provide us with permission to do so. This includes the use of professional services for example accounting, HR, debt collection and legal.

More information

For more information about your data rights and privacy or data protection in general visit the Information Commissioner’s Office website: https://ico.org.uk

How to contact us

If you have any questions about how we collect and use your information not covered in this privacy notice, or if you wish to speak to someone about our approach to data protection and privacy, please contact:

Ian Croombs (ian@croombs.co.uk)

Changes to our privacy notice

We may change or update elements of this privacy notice from time to time or as required by law. The most current version of our privacy notice is available on our website at croombs.rewindclient.co.uk

Document control

v. 1 6.6.18 Ian Croombs – First version

In this privacy policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• reference to any statutory provision includes any modification or amendment of it;
• the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Croombs Electrical Services Ltd. and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Data collected

We may collect the following Data, which includes personal Data, from you:

• Demographic information such as post code, preferences and interests;
• IP address (automatically collected);
• Web browser type and version (automatically collected);
• Operating system (automatically collected);
• A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
• in each case, in accordance with this privacy policy.

(the data collected, unless for enquiries, is via Google Analytics to identify website performance.)

Our use of Data

• For purposes of the Data Protection Act 1998, Croombs Electrical Services Ltd. is the “data controller”.
• We may retain any Data you submit for up to 14 months.
• Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
• All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (Security).
• Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
  • improvement of our products / services;
• in each case, in accordance with this privacy policy.

Enquiries

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you that have been the basis for your enquiry.

This data is not used in any generic marketing, added to any marketing database or shared with any other third parties, except selected data processors, who may have access to our website. Any enquiry data supplied is only kept for the duration of your enquiry if it does not result in a specific provision of services.

Third party websites and services

Croombs Electrical Services Ltd. may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

• Croombs Electrical Services Ltd. may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Croombs Electrical Services Ltd.. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
• We may also disclose Data to a prospective purchaser of our business or any part of it.
• In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Controlling use of your Data

Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

• use of Data for direct marketing purposes; and
• sharing Data with third parties.

Functionality of the Website

• To use all features and functions available on the Website, you may be required to submit certain Data.
• You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Accessing your own Data

You have the right to ask for a copy of any of your personal Data held by Croombs Electrical Services Ltd. (where such Data is held) on payment of a small fee, which will not exceed £10.

Security

• Data security is of great importance to Croombs Electrical Services Ltd. and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
• If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
• We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

• This Website may place and access certain Cookies on your computer. Croombs Electrical Services Ltd. uses Cookies to improve your experience of using the Website and to improve our range of services. Croombs Electrical Services Ltd. has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
• All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
• Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Croombs Electrical Services Ltd. to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
• This Website may place the following Cookies:
• Type of Cookie –
  • Purpose Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, remembering your preferences (for example, your choice of language or region).

• You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
• You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
• It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

• You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
• If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
• Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
• This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Croombs Electrical Services Ltd. reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact Croombs Electrical Services Ltd. by email at info@croombs.co.uk.

30 May 2018