PRIVACY NOTICE – CLIENTS & SUPPLIERS AND WEBSITE USE

Professional Surveillance Management (PSM) Ltd (PSM) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you deal with us or visit our website and tells you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how PSM collects and/or processes your personal data from time to time.

PSM is a “Data Controller”. This means that we are responsible for describing how we hold and use Personal Data about you. PSM may also from time to time be a “Processor” too, where we are viewing, storing or otherwise accessing images from your CCTV cameras.

A General Data Protection Regulation Procedure (Procedure 7 in our Quality Management System) exists as ensure that we manage your data securely and responsibly. This is available on request.

 

THE INFORMATION WE HOLD ABOUT YOU

We collect, store and use the following information:

  • Your forenames and surname;
  • Contact information, including your address, email address and telephone number;
  • Details in respect of your authorised users and personnel (which is required to enable us to provide our services);
  • Financial information, such as payment-related information, credit references and bank account details;
  • Marketing and communications data including your preferences in respect of receiving marketing material from us and your communication preferences;
  • Technical information, such as information from your visits to our website;
  • Other information relevant to the provision of our services; and
  • CCTV Images from your business and/or home premises.

If you are an individual whose Personal Data is processed by us as a result of us providing our services to our clients, we will collect and process a variety of different Personal Data depending on our relationship with you. This may include Personal Data relating, to any of our business clients’ or prospective clients’ officers or personnel, any supplier or purchaser Personal Data including Personal Data relating to their personnel.

If you visit our website, we may automatically collect technical data about your equipment and browsing history. We collect this personal data by using cookies. See our Cookies Policy below for more information.

If you consent to being added to our marketing database we will collect the following Personal Data from you:

  • Name;
  • Telephone number;
  • Email address; and
  • Marketing preferences.

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising and we will only contact you if we have your consent to do so.

We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us based on your marketing preferences.

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchased.

 

HOW WE USE THE INFORMATION WE HOLD ABOUT YOU

We will only use your personal data where the law allows us to do so – which includes the following circumstances:

  • the provision of services to you;
  • where we need to perform the contract we are about to enter into or have entered into with you;
  • to manage and administer our relationship 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;
  • where we need to comply with a legal or regulatory obligation;
  • to improve our services;
  • the processing of CCTV images, for the purpose of crime prevention; or
  • where you have given consent to the processing of your personal data for one or more specific purposes including marketing.

Please note that there may be circumstances where we may process your personal data without your knowledge or consent, where this is required or permitted by law.

 

HOW WE SHARE THE INFORMATION WE HOLD ABOUT YOU

We may from time to time have to share your data with the following:

  • the police and the courts;
  • regulatory authorities;
  • third parties to whom we outsource certain services such as, without limitation: chartered accountants and confidential waste disposal.
  • third party service providers to assist us with client insight analytics, such as Google Analytics.

Please note this list is non-exhaustive and there may be other examples where we need to share your Personal Data with other parties in order to provide our services as effectively as we can. Please note that any third parties with whom we share your personal data with will be screened to ensure they respect the security of your data and treat it in accordance with all applicable laws.

We will not sell, distribute or lease your Personal Data to third parties unless we have your consent to do so or we are required by law to do so.

 

HOW WE STORE AND DESTROY YOUR DATA

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All personal data is stored on the password protected PSM server within our National Security Inspectorate Gold Level CCTV remote monitoring station.

A Data Loss and Breach section exists in our Contingency Manual to mitigate the risk of software corruption, computer virus, computer theft and breach of firewalls.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out below and a Quality Management System exists to ensure that all records are retained and disposed of correctly. Documents are retained as follows:

Customer Records: Contract Life & 3 Years

Confirmed criminal activity images: 3 years after the event

All incoming alarm images (not criminal): 30 days

Records of all monitored events: 3 years after the event

Customer Complaints: Contract Life & 2 Years

Telephone Recordings: 3 months minimum

After expiry of the retention period, documents will be disposed of in the following manner:

  • Paper records destroyed by shredding.
  • Digital records on computer hard disk will be destroyed by deleting files. A defragmentation process will be completed by the qualified PC Engineer to ensure the deleted copies are removed from the Hard Drive partition.

WEBSITE

Security

PSM 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 Personal Data we collect through your use of our website.

Whilst we endeavour to protect your Personal Data, we cannot ensure the security of the information which you transmit to us. It is therefore your responsibility to take steps to protect your personal data whilst on the Internet, which may include changing your passwords often and making sure you are using a secure browser.

SSL Certificate is installed on our website for your protection. Provided by ‘Let’s Encrypt’.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

Cookie Policy

A cookie is a small file which asks permission to be placed on your browser or your computer’s hard drive.

Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you chose to do this it may prevent you from taking full advantage of the website.

We do not share the information collected by the cookies with any third parties.

 

YOUR LEGAL RIGHTS

You have the right to:

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.

You may request details of Personal Data which we hold about you. If you would like a copy of the information held on you please write to us at: Arch 11, Milk Street, Wigan, WN3 4HU.

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.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address.

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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your 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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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 could 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 one month. Occasionally it could take us longer than a month 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.

 

COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We may make changes from time to time to this privacy notice. Where it is practicable, we will notify you by email of any significant changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.