Sussex Community Internet Project Organisational Privacy Notice

v1.0 2018-05-25

Contents

  • 1. Introduction
  • 2. Who we are
  • 3. Collection of personal data
  • 4. Lawful basis for the processing of personal data
  • 5. Storage of personal data
  • 6. Security measures
  • 7. Your rights as a data subject
  • 8. Contact us
  • 9. Complaints

  1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

  1. Who we are

Sussex Community Internet Project Ltd is also known by the acronym SCIP. We provide IT Support primarily for the voluntary sector.  Our company number is 3819836. We are registered with the Information Commissioners Office.

Our registered office address is:

Sussex Community Internet Project Ltd
Community Base
113 Queens Road
Brighton
BN1 3XG
United Kingdom

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at [email protected]

  1. Collection of personal data

In carrying out our day to day activities we process and store minimal personal information relating to our clients but are required to adhere to the requirements of the Data Protection Act 1998. We take our responsibilities under this act very seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations. We operate our Data protection in compliance with BS 10012:217: Specification for a personal information management system. SCIP comply with the following national and international legislation with regards to data protection and user privacy:

SCIP primarily collect corporate data pertaining to the companies we contract with.  We do not collect personal data about individuals who work for these companies beyond first and last name and role within the organisation.  Where we contract to carry out work for an individual who is not a corporate entity we collect additional personal data in the form of a personal email address and an address for invoicing purposes.

We collect this personal data for one or more of the following purposes:

  • 1. To fulfil a contract that we have entered into with you or with the entity that you represent – typically this would be the provision of technical support services;
  • 2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services;
  • 3. To manage any communication between you and us.

The table in Section 4 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

In Section 7 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

We will not sell or swap your information with any third party.

We may share your information with our data processors. These are trusted partner organisations that work with us in connection with our organisation’s purposes. An example would be a company such as an internet service provider who we need to contract with to resolve an I.T. issue on behalf of a client. All our trusted partners are required to comply with data protection laws and our high standards and are only allowed to process your information in strict compliance with our instructions. We will always make sure appropriate contracts and controls are in place and we regularly monitor all our partners to ensure their compliance.

We may disclose your personal information to third parties if we are required to do so through a legal obligation (for example to the police or a government body); to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.

We do not share your information for any other purposes.

Visitors to our website

Our cookies and online privacy notice, which can be viewed on our website at scip.org.uk/privacy-and-cookies describes in detail how we use cookies, and we store data submitted via our contact form.

  1. Lawful basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, Group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows.

When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Purpose of collection Information category Data collected Purpose for collection Lawful basis for processing Data shared with? Retention period
1. To provide you on behalf of the entity you represent with technical support Subject matter information Name, company name, geographic location, email address. To provide appropriate online or email information about products and services that you have requested Contractual fulfilment Internally only The duration of SCIP’s contractual relationship with you or the entity you represent – typically this is assumed to be ongoing.
Telephone number Follow-up to ensure requested information meets needs and identify further requirements Contractual fulfilment Internally only
Name, address(es), email address, contact details Actual delivery of products or services, in physical or digital form, that you may have purchased from us. Contractual fulfilment Internally only
Security information e.g. administrator passwords for your I.T. systems and websites. SCIP do not store passwords for individual email accounts. Technical information that may be required for this purpose Actual delivery of products or services, in physical or digital form, that you may have purchased from us. Contractual fulfilment Internally only The duration of SCIP’s contractual relationship with the entity you represent – typically this is assumed to be ongoing.
2. Communications Contact information Names, contact details, identification details To communicate with you on behalf of the entity you represent about any issue that you raise with us or which follows from an interaction between us. To provide information about changes in services we provide including new services. Legitimate interest Internally only The duration of SCIP’s contractual relationship with the entity you represent – typically this is assumed to be ongoing.

  1. Storage of personal data

SCIP is a UK-domiciled organisation whose only offices are in the UK.

  • Our customer relationship management, marketing and accounting systems for all our businesses are either EU-based or hosted by companies participating in the EU - U.S. Privacy Shield Framework.
  • We use Cloud Service Providers (CSPs) as part of our internal processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
  • Unless we specifically state otherwise all of the CSPs that we use utilise EU-located processing facilities.
  • Our banking arrangements are based in the EU.
  • We ship and deliver physical products around the UK; we therefore use logistics companies that are based within the EU. We have appropriate legal and security relationships with those partners.
  • We resell products supplied by organisations outside the EU specifically website hosting and DNS management services. This may mean that our resale partner will have access to information about corporate data subjects who purchase their products via ourselves. The majority of websites which we host on behalf of clients are hosted in the EU.

  1. Security measures

We have what we believe are appropriate security controls in place to protect personal and corporate data held within our customer management systems.  All data is stored on encrypted, secure websites.

  1. Your rights as a data subject

As a data subject whose personal information we may hold, you have certain rights. If you wish to exercise any of these rights, please email [email protected] or use the information supplied in the Contact us section below. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

  • The right to be informed
    As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
  • The right of access
    You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
  • a) The purposes of the processing
    b) The categories of personal data concerned
    c) The recipients to whom the personal data has been disclosed
    d) The retention period or envisioned retention period for that personal data
    e) When personal data has been collected from a third party, the source of the personal data
  • If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
  • The right to rectification
    When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
  • The right to erasure (the ‘right to be forgotten’)
    Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
  • The right to restrict processing
    You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
  1. a) The accuracy of the personal data is contested
    b) Processing of the personal data is unlawful
    c) We no longer need the personal data for processing but the personal data is required for part of a legal process
    d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing
  • The right to data portability
    You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. We are only obliged to provide your data in a portable digitised format if the processing was by automated means and if the processing is based on the fulfilment of a contractual obligation.
  • The right to object
    You have the right to object to our processing of your data where

    • Processing is based on legitimate interest;
    • Processing is for the purpose of direct marketing;
    • Processing is for the purposes of scientific or historic research;
    • Processing involves automated decision-making and profiling.

  1. Contact us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to [email protected]

Alternatively, you can contact us at our registered offices using the following postal address or telephone numbers:

Sussex Community Internet Project Ltd
Community Base
113 Queens Road
Brighton
BN1 3XG
United Kingdom

Telephone: 01273 234049

Our telephone switchboard is open 9:00 am – 5:30 pm GMT, Monday to Friday. Our team will take a message and ensure the appropriate person responds as soon as possible.

  1. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. For the United Kingdom, this is the Information Commissioner’s Office (ICO), who is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.