GDPR: Data Privacy Notice for Clients and Suppliers
Twilight Zone Engineering (“We”) are committed to protecting and respecting your privacy.
This policy 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 (we do not hold special categories of personal data on clients and suppliers).
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?
Twilight Zone Engineering is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 346-348 St Albans Rd, Watford WD24 6PQ. For all data matters contact Paul Mintern on 01923 801812.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Supply of services
- Supply of goods
- Supply of IT services
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:
Personal data may include name, address, email, phone number, IT equipment information, password for equipment, history of repair, goods purchased from Twilight Zone Engineering, IP address information and domain information. If requested during booking in of Workshop repair this could also include a backup of client data.
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;|
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||SUPPLY OF GOODS AND SERVICES, MAINTENANCE CONTRACT, REPAIR REQUEST CONTRACT.|
|Processing necessary for compliance with a legal obligation||ACCOUNTING LAW- HMRC|
|Processing necessary to protect the vital interests of a data subject or another person||CCTV|
|Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller||CCTV- Compliance with law for provision of
|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||Apple and Service clients.|
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with Government, Police and suppliers of goods and services. Twilight Zone Engineering do not unless specifically asked to do so, look at any data held on your equipment.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data for legal requirements (accounting) employee – HMRC requirements. In the case of a backup during the workshop repair process this is kept on our server only and is kept until the repair has been collected.
8. Providing us with your personal data
We require your personal data as it is an accounting statutory and Apple contractual requirement. As a requirement necessary to enter into a contract.
9. 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).
10. Transfer of Data Abroad
WE TRANSFER DATA TO AMERICA, THIS DATA IS PASSWORD PROTECTED.
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.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER/OUR DATA REPRESENTATIVE- Paul Mintern on 01923 801812.
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 or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Version 1.1: May 2018