This Privacy Notice describes the relationship between Clear Day Technology LLP and your data – how it is acquired, processed and stored. It will demonstrate our respect for your data regarding security and compliance with current data protection legislation, and in particular, the General Data Protection Regulation, in effect from 25th May 2018.
Policy Updated: Monday, 23 April 2018
Accessed at: http://www.cleardaytechnology.com/dppn
Download at: http://www.cleardaytechnology.com/docs/cdt-dppnv2-1.pdf
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by [the General Data Protection Regulation 2016/679 (the “GDPR”)].
• There exists NO statutory requirement for a Data Protection Officer (DPO) for Clear Day Technology LLP
• All STAFF of the client organisation who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured
3. Who we are
Clear Day Technology LLP (“CDT”) is a provider of information technology (IT) solutions to small and medium sized enterprises (SME’s); including on-premises client/server computer systems, ‘cloud’ platform infrastructure and high-availability of data through mobile device integration; with appropriate security enabled via technology and human-interaction based policies and controls.
CDT is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
4. How do we process your personal data?
CDT complies with its obligations [under the GDPR] by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes:
- To maintain and administer accurate client records (name, address, phone, email etc)
- To effectively operate in a professional manner with third-party services to which you subscribe, as reseller and/or agent (username, password, IP address etc)
- To alert clients of technical issues and/or raise awareness of current security threats
- To inform you of pertinent technical, sales, promotional news and activities
- In liaison with known, yet temporary, technical support professionals, during periods of annual staff leave, further protected by mutual Non-Disclosure Agreement (“NDA”)
- No data is collected or retained via our website (tracking cookies etc)
- No financial data is collected or retained
5. What is the legal basis for processing your personal data?
Article 6 – “Lawfulness of processing”
Our legal basis for processing of the personal data consists of:
• Article 6.1(a) – “the data subject has given consent to the processing of his or her personal data for one or more specific purposes;”
• Article 6.1(b) – “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;”
• Article 6.4(e) – “the existence of appropriate safeguards, which may include encryption or pseudonymisation.”
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with other support professionals, under NDA, as referred to in section 4, above. We will only share your data with other third parties with your consent.
7. How long do we keep your personal data?
We keep your personal data for no longer than is reasonable, though normally for the period of contract or ‘agreement’. Personal data is not retained for any reason once any working relationship is ended.
8. 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 your personal data which CDT holds about you;
• The right to request that CDT corrects 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 for CDT to retain such data;
• The right to withdraw your consent to the processing at any time;
• The right to request that the data controller provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable);
• 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 lodge a complaint with the Information Commissioners Office
9. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection 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. Where and whenever necessary, we will seek your prior consent to the new processing.
10. Contact Details
To exercise all relevant rights, queries or complaints please in the first instance contact the Simon Beresford, CEO, Clear Day Technology LLP, 32 Coleridge Crescent, Wakefield, WF2 0LZ.
You can contact the Information Commissioners Office on 0303 123 1113 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.