Your personal data: what is it?
“Personal data” is any information about a living individual that allows them to be identified from that data (for example a name, photographs, videos, email address or address). Identification can be direct, using the data itself, or by combining it with other information which helps to identify a living individual. For example, a list of staff may contain personnel ID numbers rather than names, but if a separate list matching those ID numbers to names is used to identify the staff in the first list, then the first list is also treated as personal data.
The processing of personal data is governed by legislation relating to personal data which applies in the United Kingdom, including the General Data Protection Regulation (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act.
Who are we?
This Privacy Notice is provided to you by InteliSense IT Limited, which is the data controller for your data.
Other data controllers InteliSense IT works with
- External Audit
We may need to share the personal data we hold with them so that they can carry out their responsibilities in law. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the company and the other data controllers may be “joint data controllers”, which means we are all collectively responsible to you for your data. Where each of the parties listed above is processing your data for its own independent purposes, then each of us will be independently responsible to you, and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data InteliSense IT processes, and for what purposes, is set out in this Privacy Notice.
What personal data do we process?
The company will process some or all of the following personal data where necessary to perform its tasks:
- Names, titles and aliases, photographs.
- Contact details such as telephone numbers, addresses and email addresses.
- Where they are relevant to the services provided by InteliSense IT, or where you provide them to us, we may process information such as gender, age, marital status, nationality, education and work history, academic and professional qualifications, hobbies, family composition and dependants.
- Where you pay for our services, financial identifiers such as bank account numbers, payment card numbers, payment and transaction identifiers, policy numbers and claim numbers.
The personal data we process may include sensitive or other special categories of personal data, such as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication and treatment received, political beliefs, trade union affiliation, genetic data, biometric data, and data concerning sex life or sexual orientation.
How we use sensitive personal data
We may process sensitive personal data, as appropriate: information about your physical or mental health or condition in order to monitor sick leave and take decisions on your fitness for work; your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation; and in order to comply with legal requirements and obligations to third parties.
These types of data are described in the GDPR as “special categories of data” and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Less commonly, we may process this type of personal data where it is needed in relation to legal claims, or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent to process your sensitive personal data?
In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
Our data protection commitments
InteliSense IT will comply with data protection law. This says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept and destroyed securely, including ensuring that appropriate technical and security measures are in place to protect your personal data from loss, misuse, unauthorised access and disclosure.
Why we use your personal data
We use your personal data for some or all of the following purposes:
- To deliver services, including to understand your needs to provide the services that you request, to understand what we can do for you and to inform you of other relevant services.
- To confirm your identity to provide some services.
- To contact you by post, email or telephone.
- To help us to build up a picture of how we are performing.
- To enable us to meet all legal and statutory obligations.
- To maintain our own accounts and records.
- To seek your views, opinions or comments.
- To notify you of changes to our facilities, services, events and staff, and other role holders.
- To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, updates and other new projects or initiatives.
- To process relevant financial transactions, including payments for goods and services supplied.
- To allow the statistical analysis of data so we can plan the provision of services.
Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
What is the legal basis for processing your personal data?
This Privacy Notice sets out your rights and InteliSense IT’s obligations to you.
We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract.
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
1. The right to access personal data we hold on you
At any point you can contact us to request the personal data we hold on you, as well as why we have that personal data, who has access to it and where we obtained it from. Once we have received your request we will respond within one month. There are no fees or charges for the first request, but additional requests for the same personal data, or requests which are manifestly unfounded or excessive, may be subject to an administrative fee.
2. The right to correct and update the personal data we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
3. The right to have your personal data erased
If you feel that we should no longer be using your personal data, or that we are unlawfully using your personal data, you can request that we erase the personal data we hold. When we receive your request we will confirm whether the personal data has been deleted, or the reason why it cannot be deleted (for example because we need it to comply with a legal obligation).
4. The right to object to processing of your personal data, or to restrict it to certain purposes only
You have the right to request that we stop processing your personal data, or ask us to restrict processing. Upon receiving the request we will contact you and let you know whether we are able to comply, or whether we have a legal obligation to continue to process your data.
5. The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
6. The right to withdraw your consent to the processing at any time, for any processing of data to which consent was obtained
You can withdraw your consent easily by telephone, email or post (see Contact details below).
7. The right to lodge a complaint with the Information Commissioner’s Office
You can contact the Information Commissioner’s Office on 0303 123 1113, via email at ico.org.uk/global/contact-us/email, or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Transfer of data abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights, either through international agreements or contracts approved by the European Union.
Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on the website.
Contact details
Please contact us if you have any questions about this Privacy Notice, about the personal data we hold about you, or to exercise any relevant rights, queries or complaints:
The Data Controller, InteliSense IT Limited
Vulcan House, Pendeford Business Park, Wobaston Road, Wolverhampton WV9 5HA, United Kingdom
