Data Policy

VALVETECH SERVICES LTD – RIGHT OF ERASURE REQUEST (RIGHT TO BE FORGOTTEN) POLICY

Introduction

Individuals have the right to request erasure of their personal data in certain circumstances. Valvetec Services Ltd. must comply with the requirements of the UK General Data Protection Regulations (UK GDPR) and must be able to demonstrate compliance to the Information Commissioner’s Office (ICO).

Upon receipt of a request for erasure our internal policy is as follows:

Responsibility

Sharon Garrett, Managing Director, is responsible for the handling of right of erasure requests in the company.

The duties of Sharon Garrett include but are not limited to:

To log the receipt and fulfilment of all requests received from a data subject/the person making the request/requestor.
Acknowledge the request.
Verify the identity of any person making the request.
Maintain a database on the volume of requests and compliance against the statutory timescales.
Verify whether if the company is the controller of the data subject’s personal data.
Check if the company is not a controller, but rather a processor. If so, inform the data subject and refer them to the actual controller. This needs to be recorded in writing.
Where applicable, decide if a request is excessive, unfounded or repetitive and communicate this to the requestor.
Decide if an exemption applies.
If a request is submitted in electronic form, any information should preferably be provided by electronic means as well.

Oral or written requests

Right of erasure requests can be made in writing, electronically or verbally.

If a member of staff is in any doubt if a certain situation has given rise to a valid right of erasure, contact Sharon Garrett by email providing full details of the incident. Staff should do this without delay and certainly within TWO business days.

Where a member of staff receives a right of erasure request, they must email the relevant information to Sharon Garrett without delay and certainly within TWO business days.

How do we verify the requestor’s identity?

If we are in doubt as to the identity of the requestor, you may ask the individual to supply valid evidence to prove their identity.

We may verify the requestor’s identity either through a phone call where we ask questions that only the requestor will know the answers to or by requesting forms of identification.

We accept the following forms of identification:

Current UK/EEA Passport
UK Driving Licence
Financial Statement issued by bank, building society or credit card company
Utility bill for supply of gas, electric, water or telephonelandline]

How to process the request

Our aim is to determine the validity of the erasure request. If the request is not clear, or where if we process a large quantity of information about an individual, the UK GDPR permits us to ask the individual to specify the information the request relates to. Where this applies, we will proceed with a request for additional information.

We must respond to the data subject within 30 days of receiving the request as valid. This is a requirement under the UK GDPR.

Any employee, who receives a request from Sharon Garrett to locate and supply information relating to an erasure request, must make a full exhaustive search of the records which they are responsible for or own. This may include but is not limited to emails (including archived emails and those that have been deleted but are still recoverable), Word documents, spreadsheets, databases, systems, removable media (for example, memory sticks), recordings, paper records in relevant filing systems.

Sharon Garrett should check whether the erasure request also involves data shared with third parties or online.

If it is found to be a valid request for erasure we must comply unless an exemption can be applied (see below). Information must be supplied in an intelligible form and we must explain acronyms, codes or complex terms, where relevant.

No charge to comply with the request (with exceptions)

We must fulfil valid requests for erasure free of charge, as per the UK GDPR rules. However, we may charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive.

Where applicable, Sharon Garrett will determine the ‘reasonable fee’ that must be based on our administrative cost incurred by our business.

Excessive, manifestly unfounded or repetitive requests

Where requests are manifestly unfounded, excessive and repetitive, we may refuse to act on the request or charge a reasonable administration fee. Sharon Garrett will make a decision on this.

Sharon Garrett must provide information on our decision to the requestor in writing within 30 days and must state how they reached their decision.

Complex requests

As stated we have to respond to a request for erasure within 30 days. If more time is needed to respond to complex requests, an extension of another two months is permissible, provided this is communicated to the data subject in a timely manner and within 30 days.

Where we decide not to take action on the request of the data subject, we need to inform the data subject of this decision without delay and at the latest within 30 days of receipt of the request.

How to handle exemptions?

If a member of staff believes that we have a valid business reason for an exemption, please inform the Sharon Garrett without delay by email to sharon@valvetec-services.com.

Complaints

Where a requestor is not satisfied with a response to a request, we must manage this as a complaint. We must advise the requestor that if they remain unhappy with the outcome they may complain to the Information Commissioners Office or take legal action against us.

Breach statement

Breaches of this policy by members of staff will be investigated and may result in disciplinary action. Serious breaches of policy may be considered gross misconduct and result in dismissal without notice, or legal action being taken against the relevant member of staff.

COOKIE POLICY

A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer if you agree. These contain information that is transferred to your computer’s hard drive.

This website uses cookies to distinguish you from other users of our website. This helps us to provide a good experience when you browse this website and also allows us to make improvements to it.

We use the following cookies:

Strictly necessary cookies. These are required for the operation of this website.

Analytical/performance cookies. These allow us to recognise and count the number of visitors and see how visitors move around our website when they are using it.

Functionality cookies. These are used to recognise you when you return to this website.

Targeting cookies. These record your visit to this website, the pages you have visited and the links followed.

You can block cookies by activating the setting on your browser that allows you to refuse acceptance of all or some cookies. However, if you use your browser settings to block all cookies (including essential ones) you may not be able to access all or parts of this site.

UK GDPR DATA PRIVACY POLICY FOR WEBSITES

Please note: This document should be read in conjunction with the Guidance notes on completing the Data Privacy Policy for Websites.

This is Privacy Policy of Valvetec Services Limited

We respect your privacy and are determined to protect your personal data. The purpose of this Privacy Policy is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection laws protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

Who we are and important information
The personal data we collect about you
How we collect your personal data
How we use your personal data
Who we share your personal data with
International transfers
Data security
Data retention
Your legal rights
Changes to this notice and your duty to inform us of changes
Queries, requests or concerns

What is the purpose of this privacy notice?

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you [for example: sign up to our newsletter/purchase a product or service]

This website is not intended for children, and we do not knowingly collect data relating to children.

You must read this Privacy Policy together with any other Privacy Policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Data controller(s)

Sharon Garrett, Managing Director, is the controller and responsible for your personal data (collectively referred to as Valvetec Services Limited, “we”, “us” or “our” in this privacy notice). Contact details are:

VALVETEC SERVICES LTD. Ltd.

sharon@valvetecservices.com

Valvetec Services Ltd., 23 Robert Leonard Centre, Howe Moss Drive, Dyce, Aberdeen AB21 0GG, Scotland, UK

+44 (0) 1224 725506

Valvetec Services Limited is the controller and responsible for this website.

Third-party links outside of our control

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 Policy of every website you visit.

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes [first name/last name/ username/marital status/ title/date of birth/gender].
Contact Data includes [billing address/delivery address/email address/ telephone numbers].

[we also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. for example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. however, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.]

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Directly. You may give us your [identity, contact and financial data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services;
Subscribe to our service or publications;
Request marketing to be sent to you.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com.

Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that 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 contact Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com 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 Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact Performance of a contract with you

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.]

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Valvetec Services Limited for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time BY emailing Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transactions.

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. For more information about the cookies we use, please see our cookie policy.

Change of purpose

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties
External Third Parties Service
Providers [acting as processors] based in the UK who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.

DATA 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. 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.

DATA RETENTION

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.

Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com

YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

The right to request a copy of the personal data which we hold about you;
The right to request that we correct 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 to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means).
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 object to our processing of personal data, where applicable i.e., where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com.

No fee required – with some exceptions.

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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Sharon Garrett, Managing Director on 01224 725506 / sharon@valvetec-services.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 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, England, UK.