Frequently Asked Questions: Privacy & Data Protection
BCS’ Customer Privacy Notice
Business Cleaning Services (“BCS” / “The Company”) understands that your privacy
is important to you and that you care about how your personal data is used. We respect
and value the privacy of all of our Customers and will only collect and use personal
data in ways that are described here, and in a way that is consistent with our obligations
and your rights under the law.
1. Information About Us
3 The Drive
Data Protection Duty Holder: Administration Manager
This Privacy Information explains how we use your personal data: how it is collected,
how it is held, and how it is processed. It also explains your rights under the
law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation
2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who
can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to
be identified. Personal data covers obvious information such as your name and contact
details, but it also covers less obvious information such as identification numbers,
electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This
Privacy Notice should tell you everything you need to know, but you can always contact
us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you
how to do this.
c) The right to have your personal data rectified if any of your personal data held
by us is inaccurate or incomplete. Please contact us using the details in Part 11
to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose
of any of your personal data that we have. Please contact us using the details in
Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or
g) The right to data portability. This means that, if you have provided personal
data to us directly, we are using it with your consent or for the performance of
a contract, and that data is processed using automated means, you can ask us for
a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your
personal data in this way.
For more information about our use of your personal data or exercising your rights
as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s
Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have
the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according
to your relationship with us):
· Date of birth (this is not usually the case for commercial clients);
· Gender, usually by means of title only (e.g.: Mr, Ms, etc);
· Email address;
· Telephone number;
· Business name;
· Job title;
· Information about your preferences and interests;
· Information as disclosed by you during telephone and/or written and/or electronic
communications with the Company;
· Alarm codes;
· Door and/or gate entry codes;
· Other security codes and/or passwords;
· Payment information;
· Company registration number;
· Health information disclosed in accordance with accident reporting and/or in association
with similar matters;
· VAT number;
· Credit reference and/or score information;
Bank account details and/or card payment details.
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This
may be because the data is necessary for our performance of a contract with you,
because you have consented to our use of your personal data, or because it is in
ourlegitimate business interests to use it. Your personal data may be used for
one or more of the following purposes:
· Providing and managing your account.
· Supplying our products and/or services to you. Your personal details are required
in order for us to enter into a contract with you.
· Personalising and tailoring our products and/or services for you.
· Communicating with you. This may include responding to emails or calls from you.
This may also include:
-Responding to emergencies on Customer Premises.
-Alerting Customers to security issues or concerns.
-Managing Health and Safety matters and other similar legislation.
-Managing Customer Services and Quality Assurance.
-General service/supply management.
· Supplying you with informationby email and/or post that you have opted-in to (you
may unsubscribe or opt-out at any time by writing to DPO Duty Holder at the address
shown under Part 1, or by emailing firstname.lastname@example.org and quoting “opt-out” in
the email subject.
With your permission and/or where permitted by law, we may also use your personal
data for marketing purposes, which may include contacting you by and/or telephone
and/or text message and/or post with information, news, and offers on our products
and/or services. You will not be sent any unlawful marketing or spam. We will always
work to fully protect your rights and comply with our obligations under the GDPR
and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and
you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of
the reason(s) for which it was first collected. Your personal data will therefore
be kept for the following periods (or, where there is no fixed period, the following
factors will be used to determine how long it is kept):
· The duration of fulfilment of contract and/or for the purposes at hand, plus retention
period (ordinarily six years), and/or six financial years from point of audit of
the period pertaining to the data (whichever is the greater);
· There are some instances where data may need to be kept for significantly longer
periods of time, such instances include (but are not limited to) certain health &
safety matters (for instance matters relating to hazardous substances) that may require
permanent record, etc.
· To uphold data assurance principles, each dataset shall be considered and reviewed
upon its own merits, where longer data retention is required.
8. How and Where Do You Store or Transfer My Personal Data?
Predominantly we will only store or transfer your personal data within the European
Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway,
Iceland, and Liechtenstein. This means that your personal data will be fully protected
under the GDPR or to equivalent standards by law.
However, we may also store or transfer some or all of your personal data in countries
that are not part of the European Economic Area (the “EEA” consists of all EU member
states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries”
and may not have data protection laws that are as strong as those in the UK and/or
the EEA. This means that we will take additional steps in order to ensure that your
personal data is treated just as safely and securely as it would be within the UK
and under the GDPR as follows.
We may also transfer your data to a third party based in the US, this may be protected
if they are part of the EU-US Privacy Shield. This requires that third party to
provide data protection to standards similar levels of data protection to those in
Europe. More information is available from the European Commission.
Please contact us using the details below in Part 11 for further information about
the particular data protection mechanism used by us when transferring your personal
data to a third country.
The security of your personal data is essential to us, and to protect your data,
we take a number of important measures, including the following:
· Data access restricted to authorised personnel only;
· Data encryption;
· Avoidance of use of USB-stick flash drives; where such flash drives (or similar)
are used, your data is encrypted.
· Encryption of Company data backups.
· Predominantly, and so far as is reasonably practicable, data is stored on the Company’s
own server (utilising drive encryption).
· Use of antivirus software.
· VPN connection for remote data access; whilst such network connections shall necessarily
utilise third party software, so far as is reasonably practicable such network connections
shall not rely on third party services.
· GDPR compliant contracts, or similar data integrity assurances, with service partners
and third parties;
· Secure deletion of data, utilising multi-pass deletion of digital data from hard
drives, shredding CDs / DVDs housing digital data, shredding of paper records to
9. Do You Share My Personal Data?
We may sometimes contract with third parties to supply products and/or services to
you on our behalf. These may include, but are not restricted to, payment processing,
credit control, delivery, marketing, electronic communications transfer and/or exchange,
customer services, quality assurance, personnel and human resources management, health
and safety management, processing of insurance matters. In some cases, those third
parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we
will take steps to ensure that your personal data is handled safely, securely, and
in accordance with your rights, our obligations, and the third party’s obligations
under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps
in order to ensure that your personal data is treated just as safely and securely
as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal
data, which might include yours, if we are involved in legal proceedings or complying
with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details
of that personal data and for a copy of it (where any such personal data is held).
This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal
addresses shown in Part 11. To make this as easy as possible for you, a Subject
Access Request Form is available for you to use. You do not have to use this form,
but it is the easiest way to tell us everything weneed to know to respond to your
request as quickly as possible.
There is not normally any charge for a subject access request. If your request is
‘manifestly unfounded or excessive’ (for example, if you make repetitive requests)
a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one calendar month of receiving
it. Normally, we aim to provide a complete response, including a copy of your personal
data within that time. In some cases, however, particularly if your request is more
complex, more time may be required up to a maximum of three months from the date
we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including
making a subject access request, please use the following details: