The Data protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data.
Crimson Edge PR Ltd is a data controller within the meaning of the GDPR and we process data. The firm’s contact details are as follows:
Crimson Edge PR Ltd, 13 Essex Brae, Edinburgh EH4 6LN – Su Hesketh email@example.com
The purpose for which we intend to process personal data
We intend to process personal data for the following purposes:
- To enable us to supply services to you as our client
- To fulfil our obligations under relevant laws in force
- To comply with professional obligations to which we are subject as members of [insert any associations you are a member or report to]
- To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.
- To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
- To contact you about other services we provide which may be of interest to you if you have consented to us doing so.
The legal bases for out intended processing of personal data
Our intended processing of personal data has the following legal bases:
- At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above
- The processing is necessary for the performance of our contract with you
- The processing is necessary for compliance with legal obligations to which we are subject (e.g. building standards).
It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information the we request, we may not be able to provide services to you. If this is the case, we will not be able to commence acting or will cease to act.
Person/organisations to whom we may give personal data
We may share data with:
- Any third parties with whom you require or permit us to correspond
- An alternative appointed by us in the event of incapacity of death
- Professional indemnity insurers
- Our trade bodies (List)
- Legal Representatives / Debt Collection service providers
- Product Manufacturers (list)
If the law allows or requires us to do so, we may share your personal data with:
- The police and law enforcement agencies
- Courts and tribunals
- The Information Commissioner’s Office (ICO)
We may need to share your personal data with third parties, identified above to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties, we may cease to act.
Transfers of personal data outside the EU
Your personal data will be processed in the UK only.
Retention of personal data
When acting as a data controller and in accordance with recognised good practice within the construction sector we will retain all our records relating to you as follows:
- Finance records will be held for the purposes of VAT and tax returns for 7 years.
- Quotations will be held for 10 years
- Job details will be held for 10 years
- Maintenance plan information will be held for 2 years after the end of the contract
Where we act as a data processor as defined an DPA 2018, we will delete or return all personal data to the controller as agreed with the controller.
Requesting personal data we hold about you (subject to access requests)
You have the right to request access to your personal data the we hold. Such requests are known as ‘subject access requests’ (SARs).
Please provide all SARs in writing marked for the attention of [ ].
To help us provide the information you want and deal with your request more quickly, you should include enough relevant details to enable us to verify your identity and locate the relevant information. For example, you should tell us:
- Your name and address
- The address where work took lace
- The date when work took place
- The scope of work which took place
- Any invoice numbers relating to the work which took place
- What type of information you want to know
DPA 2018 requires that we comply with a SAR promptly and in any event within 1 month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data sine we complied with the original request).
We will not charge you for dealing with a SAR.
You can ask for someone else to request information on your behalf for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Where you are a data controller and we act for you as a data processor (e.g. service agent or installer), we will assist you with the SARs on the basis as is set out above.
Putting things right (the right to rectification)
You have the right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.
Deleting your records (the right to erasure)
In certain circumstances you have the right to have the personal date that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances, we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.
The right to restrict processing and the right to object
In certain circumstances you have the right to block or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.
Obtaining and reusing personal data (the right to data portability)
In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new service provider. Further information is available on the ICO website (www.ico.org.uk).
Withdrawal of Consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
- The withdrawal of consent does not affect the lawfulness of earlier processing
- If you withdraw your consent, we may not be able to continue to provide services to you.
- Even if you withdraw consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process data).
We do not intend to use automated decision-making in relation to your personal data.
If you have requested details of the information we hold about you and you are not happy with our response, or you think we have not complied with the GDPR or DPA 2018 in some other way, you can complain to us. Please send any complaints to Su Hesketh, Crimson Edge PR Ltd, 13 Essex Brae, Edinburgh EH4 6LN Tel: 0131 311 7050.
If you are not happy with our response, you have the right to lodge a complaint with ICO (www.ico.org.uk).