SMP Privacy Policy

SMPNews

Introduction

This Privacy Policy applies to our use of any data collected by Stuart McCurry & Partners Ltd (Company Number 04216098) in relation to your use of the website and also if you enter into a negotiation or contract with us.

In this policy, “we”, “our “or “us” refers to “the Company”

It does not extend to any websites that can be accessed from this website including any links we may provide to social media websites.

Stuart McCurry & Partners Ltd are the data controllers for purposes of the GDPR and Data Protection Act 2018 and are responsible for the manner the data you provide us with is processed.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions.

We may update and change this Privacy Policy from time to time and we advise that you regularly check this page to ensure you are happy with the changes; we will however notify you of any significant changes.

Third-party links
This 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.

Data we collect about you
Personal data, or Personally Identifiable Information (PII), means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data Information gathered using cookies in your web browser, see section how we use your cookies.

How do we collect your personal data?
We use a number of methods to collect data from you and about you including:

  • New account customer forms
  • Enquiries via the website, on email or by phone
  • Visiting us at a trade show or exchanging business cards
  • Engaging with us on social media
  • When you have given a third-party permission to share with us the information they hold for you

How we use your personal data
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.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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 grounds 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 process and deliver our services including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

 (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about our services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications		 Necessary for our legitimate interests (to develop our products/services and grow our business).

Who will we share your personal data with?
We will sometimes need to share your personal data with our trusted third parties, these can include:

  • Delivery companies
  • Third party contractors
  • 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
  • Trade Associations

 International transfers
 We do not transfer your personal data outside the European Economic Area (EEA).

Protecting your personal data
We have several GDPR compliant processes and procedures as follows:

  • All our employees handling PII have received training in GDPR and how to handle your personal data
  • Access to your personal data is restricted to the relevant employees/departments that are required to process your data
  • Where hard copies are created, these are securely kept.
  • According to each business unit’s process and procedure, your personal data will be periodically reviewed and securely deleted if required
  • All personal information is transferred by secure email to secure servers on site to which only access is granted to key personnel.

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.

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 in which we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example

  • Details of contracts are kept for 12 years in order for us to comply with our legal and contractual obligations.
  • Invoices will be kept for 7 years for legal obligations
  • Anti-money laundering: If you provide us with personal information so that we can fulfil any anti-money laundering obligations, we will retain such information for a period of 5 years – this is to fulfil our legal obligations.

Your legal rights over your personal data
You have the rights under the data protection laws in relation to your personal data including:

  • 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 out of date 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 business or legal 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 at smp@smpengineering.co.uk requesting for Data Subject Access Request if you wish to exercise any of these rights.

  • No fee in most cases – 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. There is the possibility that we will refuse to comply with your request in these circumstances.
  • What we may need from you – to protect your personal data we will ask you to verify your identity before proceeding with your request 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.

If you have authorised a third party to submit a request on your behalf, we will request proof that they have your permission to do so.

  • Time limit to respond – We will respond to all legitimate requests within 1 month from the date of receipt of your request. Occasionally it may take us longer if your request is particularly complex or you have made several 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.

Complaints
We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact our Privacy Officer.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

  • Report a concern online at https://ico.org.uk/concerns/
  • Call 0303 123 1113
  • Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Contact us
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Officer:

Email : caroline@smpengineering.co.uk

Telephone : 01296 696780

 

Stephen Gates
Managing Director                                                                             January 2020