1 - OVERVIEW
We take data protection and your privacy very seriously.
1.1 NSI (HQ) Ltd is committed to protecting the privacy and security of your personal data/information and complying with our obligations under the Data Protection Act 2018 (the ‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in respect of data privacy and security. We have a duty to notify you of the information contained in this policy. The Company takes the security and privacy of your data seriously. We need to gather and use information or ‘data’ about you as part of our business and to manage our relationship with you.
1.2 NSI (HQ) Ltd (t/a Scan2Protect) undertakes never to pass your data on to any third party, apart from the information necessary for delivery purposes. We are registered under the Data Protection Act and now comply with the General Data Protection Regulation (GDPR) and maintain your details securely.
1.3 In return for our data protection undertakings to you we ask that the data you supply us is both accurate and complete. If it is not, or we reasonably suspect it is not, we reserve the right not to fulfil orders placed.
1.4 We do not store credit card details nor do we share customer details with any 3rd parties outside of the need to provide you with the goods and/or services we are supplying (eg your address information may be supplied to a courier for the purposes of delivery).
1.5 The Company has measures in place to protect the security of your data in accordance with our Data Security Policy.
1.6 The Company is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. We will appoint a designated, named Data Controller as a contact.
1.7 This policy explains how the Company will hold and process your information. It explains your rights as a data subject.
If you have any queries regarding data protection or your privacy, please feel free to contact Us.
2 - DATA PROTECTION PRINCIPLES
Personal data must be processed in accordance with six 'Data Protection Principles.' It must:
- be processed fairly, lawfully and transparently;
- be collected and processed only for specified, explicit and legitimate purposes;
- be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
- be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
- not be kept for longer than is necessary for the purposes for which it is processed; and
- be processed securely.
3 - HOW WE DEFINE PERSONAL DATA
3.1 ‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
3.2 This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
3.3 This personal data might be provided to us by you, or someone else (eg a third party supplier such as a maintenance company, a reseller or store from which you have purchased a product), or it could be created by us when you register your product or make a purchase.
3.4 The information we retain will be sufficient for us to be able to properly supply you with the goods and/or services you have contracted to purchase such as your address, telephone number and email together with such details of the product as would be reasonable to allow us to support you and validate any warranty claims that may arise.
4 - SPECIAL CATEGORIES OF INFORMATION
'Special categories of personal data' are types of personal data consisting of information as:
- your racial or ethnic origin;
- your political opinions;
- your religious or philosophical beliefs;
- your trade union membership;
- your genetic or biometric data;
- your health;
- your sex and sexual orientation; and
- any criminal convictions and offences.
Where relevant we may hold elements of these in accordance with the law.
5 - HOW WE DEFINE PROCESSING
'Processing' means any operation which is performed on personal data such as:
- collection, recording, organisation, structuring or storage;
- adaption or alteration;
- retrieval, consultation or use;
- disclosure by transmission, dissemination or otherwise making available;
- alignment or combination; and
- restriction, destruction or erasure.
This includes processing personal data which forms part of an electronic or paper based filing system.
6 - HOW WE PROCESS YOUR DATA
6.1 The Company will process your personal data (including special categories of personal data) in accordance with our obligations under the 2018 Act.
We will use your personal data for:
- performing the contract for goods/services between us;
- complying with any legal obligation; or
- if it is necessary for our legitimate interests
6.2 However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing.
6.3 We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.
6.4 If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the contract between us. For example, if you do not provide us with details which affect your VAT waiver we may be unable to offer you VAT relief on goods and services.
6.5 We do not take automated decisions about you using your personal data or use profiling in relation to you.
7 - SHARING YOUR PERSONAL DATA
7.1 Sometimes we might share your personal data with group companies or our contractors and agents to carry out our obligations under our contract with you or for our legitimate interests. This would be limited to information such as may be essential in order to supply any goods/services you have purchased from us (eg couriers or third party maintainers).
7.2 We require those companies to keep your personal data confidential and secure and to protect it in accordance with the law and our policies. They are only permitted to process your data for the lawful purpose for which it has been shared and in accordance with our instructions.
8 - BREACHES
We have robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur (whether in respect of you or someone else) then we must take notes and keep evidence of that breach. If the breach is likely to result in a risk to the rights and freedoms of individuals, then we must also notify the Information Commissioner’s Office within 72 hours.
9 - SUBJECT ACCESS REQUESTS – WHAT INFORMATION WE HOLD ABOUT YOU
9.1 If you would like to make a SAR in relation to your own personal data, you should make this in writing to the Data Controller. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.
9.2 There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
10 - YOUR DATA SUBJECT RIGHTS
10.1 You have the right to information about what personal data we process, how and on what basis as set out in this policy.
10.2 You have the right to access your own personal data by way of a subject access request (see above).
10.3 You can correct any inaccuracies in your personal data. To do you should contact us by writing.
10.4 You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact us by writing.
10.5 While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact us in writing
10.6 You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
10.7 You have the right to object if we process your personal data for the purposes of direct marketing.
10.8 You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month.
10.9 With some exceptions, you have the right not to be subjected to automated decision- making.
10.10 You have the right to be notified of a data security breach concerning your personal data.
10.11 In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact us in writing
You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.