GDPR: DATA PRIVACY NOTICE FOR CLIENTS, CONSULTANTS AND SUPPLIERS

Introduction

SelwayJoyce Limited is committed to protecting and respecting your privacy.

This policy (together with standard terms and conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation 2018 (the “GDPR”).

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

SelwayJoyce Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:

9 Upper Hight Street, Winchester, Hampshire, SO23 8UT

Email:admin@selwayjoyce.co.uk

Tel: 01962 840630.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

To deliver the services you have asked us to provide to you in relation to any project

To maintain contact and communication with you during the course of a potential or new project.

To maintain contact in a professional capacity within the fields Quantity Surveying, Contract Administration (including Employers Agent in this context) and Project Management.

To maintain our own records and accounts.

To inform you of news, events or activities.

To purchase goods, materials and services from you.

To use Third Parties to provide services connected to the potential or new project

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

ە Personal data may include your name, address, email address, phone number, financial data for payments such as VAT registration and bank details.

We have obtained your personal data from you, your employees or from publicly available data from websites.

5. What is our legal basis for processing your personal data?

a. Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

Consent of the data subject:

ە Data for communications, marketing purposes and for sending out satisfaction surveys.

Performance of a contract with the data subject:

ە Running the business
ە Scoping potential services/ projects
ە To provide all services under the applicable contract with you
ە To instruct any Third Party in relation to the potential projects and/ or to assist in the delivery of the services/ project you have asked us to deliver
ە Data for communications, marketing purposes and for sending out satisfaction surveys.

Legitimate interest:

ە Maintaining contact in a professional capacity within the fields of Quantity Surveying, Contract Administration (including Employers Agent in this context) and Project Management.
ە Data used for the purposes of purchasing supplies, materials and third party services for the legitimate running of the business
ە Data held for commercial, Quantity Surveying and historical interest
ە Data for communications, marketing purposes and for sending out satisfaction surveys.

b. Special categories of personal data (article 9 of GDPR)

Our lawful basis for processing your special categories of data:

ە N/A

6. Sharing your personal data

Your personal data will be treated as strictly confidential and will be shared only with directors, HR administrative, finance staff, and contact details with members of the design team. Data may also be shared with Third Parties who are instructed by us to assist in delivering services you have instructed us to provide.

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary. Examples include: in case of any legal claims/complaints, accounting etc., for example for accounting purposes we must keep records for 6 years or longer from the end of the last company financial year they relate to. In some cases there is a need to retain project data for over the 6 year period for commercial, Quantity Surveying and historical interest.

8. Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data, but failure to do so may have consequences in relation to the services that we can offer or communications.

9. Your rights and your personal data

You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

In relation to a Subject Access Right request, you may request that we inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond.

We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.

If you wish to make a Subject Access Request, please send the request to SelwayJoyce Limited, 9 Upper High Street, Winchester, Hampshire, SO23 8UT or email admin@selwayjoyce.co.uk marked for the attention of the Data Compliance Officer.

10. Transfer of Data Abroad

We do not generally transfer personal data outside the EEA, unless on a project by project basis the client or main supplier is a company based outside the EEA, in which case project team contact details may be shared with them for communication purposes only. Some of these entities may be located in countries that do not provide an equivalent level of protection as the EEA. Where required to transfer, we will implement appropriate cross-border transfer solutions to provide adequate protection for transfers of certain information.

11. Automated Decision Making

WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data 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.

13. Cookies

Some of our web pages utilise “cookies” and other tracking technologies. Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ’session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by other websites who serve up content on that site (‘third party cookies’).
Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our web site and your web experience. We may also analyse information that does not contain personal information for trends and statistics.

14. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check the website periodically to see any updates or changes to our privacy policy.

15. How to make a complaint

To exercise all relevant rights, queries or complaints, please in the first instance contact the us at the contact details above.

We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk).

SelwayJoyce Limited, May 2018

2. Who are we?

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