Rawlings CMS Limited T/A Trust IT Systems are committed to protecting your personal data and we want you to understand the choices and control you have over your information.
The new General Data Protection Regulations (GDPR) comes into force on 25th May 2018. Some of the changes to how data is stored and/or processed are highlighted below:
The GDPR gives individuals in the EU more control over how their data is used and places certain obligations on businesses that process information of those individuals.
Transparency: We’ve provided additional details about the information we collect and how we use that information. We’ve also explained your choices and the control you have over your information.
Functionality: We may provide you with the ability to access and request correction or deletion of your personal information.
We hold various data on your organisation which may include but is not a definitive list:
Various Telephone numbers and Email addresses supplied by yourself
VAT and company registration number
Bank Account details
The information we hold is only used for the purposes of trading and communicating with yourselves and is stored within our secure in-house server. We have never and will never pass your personal data on to a third party without your express permission.
To comply with the new GDPR regulations we require your consent to us holding your data on file, if you have not replied by Friday 25th May 2018 we will assume you consent.
If you do not consent or wish to check any data we hold please contact email@example.com and we will provide you with the information requested or remove your records from our database immediately.
We are Rawlings CMS Ltd T/A Trust IT Systems registered in England and Wales, Company number 8138243. VAT Number: GB 139228112
Postal address: Rawlings CMS Ltd, Bell Road, Basingstoke, Hampshire, RG24 8FB
Telephone number:01256 760364
Email address: firstname.lastname@example.org
Manager: Simon Light
What we collect
We may collect the following information:
Identity Data: Name and job title
Contact Date: Business Contact information including email address and telephone number
Demographic information such as postcode and preferences
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity, contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you request our delivery service.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Under a Performance of Contract. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where we need to comply with a legal or regulatory obligation.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services.
We will not use your information to contact you for market research purposes. We only use your personal data for the purpose of fulfilling your order with us.
We do not sell or share your personal data with any third party.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of Legitimate Interest
To register you as a new customer (a) Identity
(b) Contact Performance of a Contract with you
To manage our relationship with you which will include:
(c) Profile (a) Performance of a Contract with you
(b) Necessary to comply with a legal obligation
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Change of purpose
We will only use your personal data for the purposes for which we collected it.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties. Other companies in our group acting as joint controllers or processors and that provide IT and system administration services and undertake reporting.
External Third Parties. Including service providers acting as processors or hosts who provide IT and system administration services and service agents for support and delivery companies for the transportation of products.
Professional advisers acting as processors or joint controllers including solicitors, barristers, bankers, auditors and insurers based in the United Kingdom or EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Government Agencies for example for fraud or illegal activities.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data: see Request erasure of your personal data, below for further information.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as listed below:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please email us on email@example.com if you wish to exercise any of these rights.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within thirty (30) calendar days from the date of receipt of your request. Occasionally it may take us longer, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Where you are sending us a request via post rather than email we recommend you send it via recorded delivery to guarantee safe delivery.
ICO, Data Protection Act 1998 and GDPR
We adhere to the following principles:
access to your information is restricted to our relevant trained staff only;
where any hard copies are created, the hard copies of your information and confidential documents are kept securely under lock and key.
All our relevant employees have received training in how to handle your information. This includes ensuring they are aware of the importance of handling your information safely and securely and understanding the procedures in place to ensure this happens.
We periodically evaluate our database and securely delete any contacts no longer engaged or any information no longer needed by us.
We have measures in place to keep your information we hold safe and secure.
All personal information is transferred by secure email to secure servers on site to which access is granted to key personnel. Where your information is downloaded to be updated, and as a backup to the cloud, it is only stored on personal drives, only accessible via individual login.
Nothing herein contained shall give rise to a partnership or a contract of employment between you and us.
No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term.
If you wish to learn more information or have a question about your Personal Data or cookies please email us on firstname.lastname@example.org , telephone 01256 262080 or write to us at: Rawlings CMS Ltd, Bell Road, Basingstoke, RG24 8FB