Milton Keynes Security Ltd Privacy Notice and Consent

Version: 1 Date: 01.05.2018

At Milton Keynes Security Ltd we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. We will never sell, share or use your personal information other than as described here.

About This Privacy Policy

This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Milton Keynes Security Ltd and how we process your data.

Who We Are, And How To Contact Us

Milton Keynes Security Ltd is registered in England and is registered with the Information Commissioner’s Office under the Data Protection Act 1998. The data controller is: Marie Stevens.

 You can get in touch with us in any of the following ways:

Email: marie@mksecurity.co.uk or info@mksecurity.co.uk

Phone: 01908 644007 (office hours)

Website: www.mksecurity.co.uk

Post: Unit 2 Wharfside, Fenny Stratford, Milton Keynes, MK2 2AZ

How to change your Preferences

You can visit the Milton Keynes Security Ltd website (www.mksecurity.co.uk) to contact us to change your preferences at any time. You can also call or email us using the details listed above.

How we Operate

We operate in line with EU GDPR (May 2018) data protection guidelines. We are committed to maintaining your personal rights and allow all users to change or withdraw their opt-in options at any time. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office.

We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Who this privacy policy applies to

This policy relates to users of Milton Keynes Security Ltd and associated suppliers. Processing of your data is required in order to offer you these services. This policy applies to individuals who have registered with Milton Keynes Security Ltd as either a customer, user, administrator or in any other capacity. 

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 collect information about criminal convictions and offences for BS7858 Security Screening for Employees.

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. 

This includes (as a customer):

• Information you provide during the registration process 
• Information we collect about how you use the website
• Information relating to how you use our services and other transactions
• Information given and stored as part of our ongoing relationship

Scope of Agreement

By submitting your personal data on this site, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to amend your preferences at any time by the methods described.

Opting out at a later date

Once you have given your agreement, you can change your preferences at any time. You can also choose to object to processing at any time. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please visit Milton Keynes Security Ltd or contact us using the details above.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

We respect all your rights as defined under the current data protection laws including GDPR (2018). You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We 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 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 to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How we store and process your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information. We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your account data will be collected stored and processed within the UK & Ireland only. Your data will be stored as described here or until you request removal of your personal data from our system. Please note that we will be unable to carry out your request to be removed it there is still and open transaction against your account. In order to provide updates and offers that may be of interest to you we use recognised third parties to take payment, manage our company accounts and provide banking services. We will store transactions, payment (this does not include payment card data) and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU.

We will only use your personal data when legally permitted.  

The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

To register you as a new customer

To process and deliver your service including managing payments, fees and charges, and to collect and recover money owed to us

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity, (b) Contact

(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications

(a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications

(a) Identity, (b) Contact, (c) Technical

(a) Technical, (b) Usage

(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile

Lawful basis for processing

Performance of a contract with you

(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us

(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

Necessary for our legitimate interests to develop our products/services and grow our business. Also based on your explicit consent to receive marketing information.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. 

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We do not use profiling or other forms of automated processing other than as described here.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Our Obligations

We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the Data Protection Act 1998 and the GDPR (2018) in the way we use and share your personal data. Among other things, this means that we will only use your personal data:

• Fairly and lawfully
• As set out in the legislation and this policy
• To the extent necessary for these purposes

We will from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Third Parties

Your data is not shared with any third parties other than as described here.

• The data you submit during the purchase of your product.
• By giving consent during the purchase of your product to send you marketing information about goods and services that they think you may be interested in, as well as account management or relationship management purposes. 

In addition we may have to share your personal data with the parties set out below for the purposes set out in the table above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, SSAIB, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you have any queries or concerns about your data usage please contact us.

Legitimate Interests

Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

Contacting us, exercising your information rights and Complaints

If you any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact us. We will process SARs within 20 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

An introduction to cookies

A cookie is a small data file that is automatically placed onto your computer's hard drive. Cookie files are created by our website and placed onto your device in order to analyse and influence your preferences or behavior. Analytical cookies are designed to track your journey and experience on our website - so that we may tailor your experience and gather data. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. The majority of modern web browsers will automatically allow cookies to be placed onto your device. However you can usually modify your browser's settings in order to prevent any cookies from being placed onto your device. Setting your browser to block cookies may prevent you from taking full advantage of our website.

Cookies deployed by our website:

Cookies are not deployed to:

Your consent for cookie deployment by our website.

Upon your first visit to our website, you may have noticed our banner alerting you to the use of cookies by our website. In compliance with the 2011 EU Cookie Law, our website operates on an 'Implied Consent' basis. This means that we have assumed that you have 'opted-in' for our website to deploy cookies until you choose to deactivate them within your browser settings or via the instructions below. Below you can learn more about the specific cookies deployed by our website, and how they can be disabled. For more information on the EU Cookie Law in the UK, we recommend visiting the Information Commissioner's Office (ICO) website where you can find the latest information, guidelines and advice on the EU Cookie Law.

Cookies used by our website

• Social Network Sharing

  We encourage users to share our content and/or like our on profile on the popular Social Media websites Facebook, Twitter, YouTube, Google+ and LinkedIn. In order to make 'Social Sharing' accessible, our website utilises widgets either provided directly from the Social Networks and/or via amalgamative widgets from third parties such as AddThis. Cookies and privacy implications from the social networks vary and will be dependent on your nominated privacy settings with each Social Network. Social Sharing buttons will only deploy cookies if you are signed to that respective Social Network at the time of being on our website.

• Analytical Tracking

  Our website has Google Analytics installed which allows us to track and compile anonymous visitor statistics. The information collected ranges from simple traffic volume to the type of browser you are viewing our website with. This information is valuable to us not just for marketing analysis and quantification, but to improve the usability, security and load speed of our website content. Google Analytics is a popular, secure, flagship webmaster product from Google. The privacy and security of Google Analytics data is a high priority at Google that you can read more about on Google's Analytics Data Safeguarding page. Google also offer a Google Analytics Opt-out Browser Add-on that will allow you to automatically Opt-out of all websites that track your activity via Google Analytics. No personal information is collected by Google Analytics.

• Cookie Consent Check

  Upon your first visit to our website, you will notice a subtle banner on the page alerting you to the fact that cookies are being placed onto your computer by our website. In order for our website to remember your choice of opting-in, we store a cookie which expires after the set amount of days below (see table).

• Wordpress

  Our website, either in full or in part, is built on the popular open-source CMS framework - WordPress. WordPress utilises cookies to allow visitors to register, login and comment on our website's content. If you do not wish to participate in commenting on our website, Wordpress will not deploy any cookies onto your device. Cookies will only be created by Wordpress if you actively register or comment via the clear forms on our website.

• Enquiry Forms

  Our website's visitors can choose to contact us via form(s) on our website. In order to prevent spam enquiries, we protect our forms with anti-spam challenges which ensure the visitor is an actual living person, rather than a computer bot or spider.

Actual cookies deployed

Below is a table of information which lists all cookies deployed and used on our website.

Cookie Category	Cookie Name	Cookie Description
Cookie Consent	complianceCookie	This cookie is set by our website once you have seen and acknowledged our Cookie banner. This cookie will expire and automatically delete itself after [30] days.
Google Analytics (Universal)	_ga, _gat	The single default cookie for Google Universal Analytics. This sole cookie used by Goole Analytics stores a unique client identifier (Client ID) which is set randomly. This cookie is set to expire after 24 months (2 years) and is refreshed each time you visit our website.
	_utmb	A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor enters a site.
	_utmc	A Google Analytics cookie, which creates a timestamp of the exact moment when a visitor leaves the site.
	_utmv	Used for reporting in Google Analytics classifying the visitor.
	_utmz	A Google Analytics cookie which tracks where the visitor came from, what search engine was used, what link was clicked on, what keywords used, and where in the world the site was accessed from.
WordPress	wp-settings-{time}-[UID]	Serveral WP Settings cookies may be set if you log into the website. The number on the end is your individual user ID from the users database table. This is used to customise your view of admin interface, and possibly also the main site interface.
	wordpress_test_cookiewordpress_wordpress_logged_in	These WordPress session cookies are created if and when you log into WordPress either as an administrator or contributor to the website.
	devicePixelRatio	This cookie records your device's pixel ratio. If your screen resolution is a retina or Hi DPI screen, then the website may choose to serve you higher resolution graphics.

How to disable cookies

Most modern browsers allow you to control your cookie settings for all websites that you browse. You can disable cookie deployment completely by editing your browser settings, however in doing this you may be limiting the functionality that is displayed on our website. To learn how to disable cookies on your preferred browser we recommend reading this advice posted by Google.

If you are concerned about cookies tracking your movements on the Internet then you may be concerned about spyware. Spyware is the name given to a particular band of cookies that track personal information about you. There are many antispyware programs that you can use to prevent this from happening. Learn more about antispyware software - https://en.wikipedia.org/wiki/Spyware. You call also disable Google Analytics on all websites by downloading the Google Analytics Opt-out Browser Add-on.