2. Personal data protection principles
We adhere to the principles relating to the Processing of Personal Data set out in the GDPR which require Personal Data to be:
- 2.1 Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
- 2.2 Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
- 2.3 Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
- 2.4 Accurate and where necessary kept up to date.
- 2.5 Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed.
- 2.6 Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
- 2.7 Not transferred to another country without appropriate safeguards being in place.
- 2.8 Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data.
The Company is responsible for and must be able to demonstrate compliance with the data protection principles listed above.
3. Lawfulness, fairness, transparency
Personal data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. We only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent processing, but ensure that we process Personal Data fairly and without adversely affecting the Data Subject. The GDPR allows Processing for specific purposes, some of which are set out below:
- 3.1 the Data Subject has given his or her Consent;
- 3.2 The processing is necessary for the performance of a contract with the Data Subject;
- 3.3 To meet our legal compliance obligations;
- 3.4 To protect the Data Subject's vital interests;
- 3.5 To pursue our legitimate interests for purposes where they are not overridden because the processing prejudices the interests or fundamental rights and freedoms of Data Subjects.
4. How we collect your data
4.1 Data You Provide
4.2 The Data Collected
- Contact Data: Your e-mail address, name, job title, company name, address, telephone number, post code, country, industry, etc.
- Financial data: Your bank account number, sort code or IBAN, bank address.
- Identity data: Your IP address, browser type, hostname, browsing device details, etc.
- Website browsing data: pages visited, form validation errors, time spent on our web pages, activity on our web pages, etc. We only ask for data through forms on our website that we intend to use to help improve your interaction and consumer experience.
- Sensitive personal data: If you are a Sovereign Connections Limited employee we may collect some health related information, should you choose to provide it, travel related data and information collected as part of a background check.
4.3 Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. We will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. We check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We also take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.
6. Storage limitation
Personal Data is not kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless there is a legal requirement such data to be kept for a minimum time.
The Company will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company's applicable records retention schedules and policies. This includes requiring third parties to delete such data where applicable.
The Company is required under UK tax law to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
7. Data Subject's rights and requests
Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:
- 7.1 Withdraw Consent to processing at any time;
- 7.2 Receive certain information about the Data Controller's processing activities;
- 7.3 Request access to their Personal Data that we hold;
- 7.4 Prevent our use of their Personal Data for direct marketing purposes;
- 7.5 Ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data;
- 7.6 Restrict processing in specific circumstances;
- 7.7 Challenge processing which has been justified on the basis of our legitimate interests or in the public interest;
- 7.8 Request a copy of an agreement under which Personal Data is transferred outside of the EEA;
- 7.9 Object to decisions based solely on Automated Processing, including profiling (ADM);
- 7.10 Prevent processing that is likely to cause damage or distress to the Data Subject or anyone else;
- 7.11 Be notified of a Personal Data breach which is likely to result in high risk to their rights and freedoms;
- 7.12 Make a complaint to the supervisory authority;
- 7.13 In limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.
The Company may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure required 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.
8. Record keeping
The GDPR requires us to keep full and accurate records of all our data processing activities. The Company will keep and maintain accurate corporate records reflecting our processing including records of Data Subjects' consents and procedures for obtaining consents.
|Automated Decision-Making (ADM):||When a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.||Automated Processing:||Any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.|
|Company name:||Sovereign Connections Limited||Company Personnel:||All employees, workers [contractors, agency workers, consultants,] directors, members and others.|
|Consent:||Agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.||Data Controller:||The person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.|
|Data Subject:||A living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.||Data Privacy Impact Assessment (DPIA):||Tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.|
|Data Protection Officer (DPO):||The person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.||EEA:||The 28 countries in the EU, and Iceland, Liechtenstein and Norway.|
|Explicit Consent:||Consent which requires a very clear and specific statement (that is, not just action).||General Data Protection Regulation (GDPR):||The General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.|
|Personal Data:||Any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.||Personal Data Breach:||Any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data breach.|
|Privacy by Design:||Implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.||Privacy Guidelines:||The Company privacy/GDPR related guidelines provided to assist in interpreting and implementing this Privacy Standard and Related Policies.|
|Pseudonymisation or Pseudonymised:||Replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.||Sensitive Personal Data:||Information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.|