GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
AAC Service & Maintenance Ltd (“We”) are committed to protecting and respecting your privacy.
This policy (and any other documents referred to on 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 (the “GDPR”).
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.
- Who are we?
AAC Service & Maintenance Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: AAC Service & Maintenance Ltd, registered office 42 Lytton Road, Barnet, Herts EN6 6BY. Email: firstname.lastname@example.org. Contact/Trading address: Unit 6 Mallow Park, Watchmead, Welwyn Garden City, Hertfordshire AL7 1GX, Tel: 01707 325566. email@example.com. For all data matters contact Michelle Smith on 01707 325566 or email firstname.lastname@example.org.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To provide the services that you request from us.
- To provide quotations, advice and information on services that you request from us.
- To manage payments and comply with HMRC rules and requirements.
- To maintain our own accounts and records.
- To manage our employees.
- To inform you of products and services that we provide.
- 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:
- Personal data
Identity Data: includes FIRST NAME AND LAST NAME.
Contact Data: includes email address/ telephone numbers].
Financial Information: includes BANK DETAILS for suppliers/sub contractors together with TAX DETAILS for suppliers/sub contractors for HMRC purposes.
We have obtained your personal data directly from information supplied by filling in the online Contact forms or by corresponding with us by post, phone, email or otherwise.
- What is our legal basis for processing your personal data?
- Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||Provision of mechanical and electrical maintenance and installation services under formal contract.|
|Processing necessary for compliance with a legal obligation||HMRC Compliance in relation to Supplier and Sub Contractor payment and other related HMRC requirements.|
|Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||Provision of mechanical and electrical maintenance and installation services, advice and information.|
- Special categories of personal data (article 9 of GDPR)
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
More information on lawful processing can be found on the ICO website.
- Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with:
- AAC Approved suppliers and sub contractors as necessary to carry out the services you require from AAC.
- AAC appointed Accountants as necessary to complete end of year financial reports for Companies House and HMRC.
- AAC Appointed IT Support to administer and maintain our database and IT infrastructure.
- How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and in line with the chart below:
|Active Customer Details||Indefinitely whilst still a customer||For performance of services|
|Non Active Customer Details –||6 Years from completion of last service provision||For warranty issues, legal claims/complaints and compliance with HMRC|
|Financial/Accounting Information||6 years from end of financial year||To comply with HMRC rules|
|NICEIC Certificates (excluding MCS Jobs)||5 Years||To comply with NICEIC rules|
|MCS Certificates and associated information||10 years||To comply with MCS rules|
- Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
We do not transfer personal data outside the EEA.
- Automated Decision Making
We do not use any form of automated decision making in our business.
- 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.
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Michelle Smith on 01707 325566 or email email@example.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.