Privacy policy.
Archernar Limited customer privacy notice
Registered name: 16040280
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
Contact details
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Occupation
· Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Information relating to compliments or complaints
· Website user information
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Purchase or service history
· Account information, including registration details
· Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
· Names and contact details
· Marketing preferences
· Purchase or account history
· Website and app user journey information
· IP addresses
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Any other personal information required to comply with legal obligations
We collect or use the following personal information for recruitment purposes:
· Contact details (eg name, address, telephone number or personal email address)
· Date of birth
· National Insurance number
· Copies of passports or other photo ID
· Employment history (eg job application, employment references or secondary employment)
· Education history (eg qualifications)
· Right to work information
· Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
· Security clearance details (eg basic checks and higher security clearance)
· Names and contact details
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
· Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
· Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We use information gathered from prospects and customers to identify how to improve the services we offer to them. The benefits include; products and services more suited to customer needs, more targeted information shared with prospects and customers, less irrelevant information shared with prospects and customers.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
· Directly from you
· Publicly available sources
How long we keep information
Statement of Purpose
1. Archernar Limited (the Organisation, we, our or us) is committed to adhering to the data protection and privacy rights of all individuals whose Personal Data it Processes in the course of its activities. To do so, we are committed to meeting the requirements imposed by UK Data Protection Laws: particularly, requirements under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This Data Retention Policy is implemented to this end, with a focus on the storage limitation principle.
2. This Data Retention Policy is based on the UK Data Protection Laws. If this Policy is at any time inconsistent with this body of law, Archernar Limited will act (including by adjusting any relevant Retention Periods) to meet the requirements imposed by up-to-date UK Data Protection Laws in priority to the requirements set out in this Policy.
3. Any questions in relation to this Policy should be referred to the data protection officer in the first instance, via email at info@archernardata.com.
Definitions, Interpretation, and Scope
4. Within this Policy, the following terms hold the following meanings:
a. ‘Condition for Processing’ means the exceptions to the general prohibition on Processing Special Category Personal Data, specified by UK Data Protection Laws, at least one of which must apply to Processing of Special Category Personal Data for that Processing to be in compliance with UK Data Protection Laws;
b. ‘Data Protection Principles’ means the 7 core principles at the heart of the UK Data Protection Laws, which these laws are constructed to uphold;
c. ‘Data Subject’ means the individual to whom an item of Personal Data relates and who can be identified from this data;
d. ‘Lawful Bases’ means the 6 grounds set out in Article 6 of the UK GDPR, at least one of which must apply to Processing of Personal Data for that Processing to be in compliance with UK Data Protection Laws;
e. ‘Personal Data’ means any information relating to an individual who can be identified (either directly or indirectly) by this information. References to Personal Data within this Policy refer to all Personal Data that the Organisation Processes, including any Personal Data that the Organisation stores following use of this data in the course of its work with or via agents, consultants, sub-contractors, or similar;
f. ‘Processing’ means any use of Personal Data outside of private personal use, including obtaining, recording, managing, using, storing, or anonymising this data;
g. ‘Special Category Personal Data’ means the certain types of personal data that the UK Data Protection Laws identify as being more sensitive in nature than other Personal Data and, consequently, as requiring a higher level of protection; including information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and biometric data;
h. ‘UK Data Protection Laws’ means any law applicable in the UK relating to the Processing of Personal Data, including but not limited to the UK GDPR and the Data Protection Act 2018.
5. The definitions above apply also to the singular or plural, other tense, or other form of such words when used within this Policy.
Legal Justification for Processing
6. Archernar Limited is committed to ensuring that all Processing of Personal Data carried out by us and/or our agents, sub-contractors, consultants, employees, or others working on our behalf is carried out in compliance with UK Data Protection Laws. As such, we confirm that:
a. All Personal Data is Processed in reliance on one or more of the Lawful Bases;
b. All Special Category Personal Data is, additionally, Processed in reliance on a separate Condition for Processing; and
c. All Processing is carried out in accordance with the Data Protection Principles.
7. All necessary documentation and procedures are completed and in place to ensure that all Processing is carried out in accordance with UK Data Protection Laws and the Data Protection Principles (e.g. the transparency and accountability principles).
a. Access to documentation can be requested from the data protection officer by emailing info@archernardata.com. Access will be granted where it is appropriate to do so (e.g. with regard to other individuals’ data privacy and to business confidentiality needs).
Storage Limitation
8. This Data Retention Policy deals primarily with how we will uphold the Data Protection Principle of storage limitation. The storage limitation principle requires that we do not keep (e.g. store) Personal Data for any longer than we need it, with ‘need’ determined by reference to the purposes and Lawful Bases for which given Personal Data is Processed.
9. Adhering to the storage limitation principle is vital for:
a. Reducing the risks of data breaches and other security threats to data’s privacy and integrity;
b. Reducing the risk of Personal Data becoming irrelevant, excessive, inaccurate, out-of-date; or being used incorrectly or by accident; and
c. Reducing the Organisation’s legal risk by ensuring that Personal Data is not retained once the applicable Lawful Bases(s) no longer apply (i.e. once it can no longer be Processed in accordance with UK Data Protection Laws).
10. To uphold the storage limitation principle, Archernar Limited’s commitments include (but are not limited to):
a. Adhering to the Retention Periods set out in the schedule to this Policy titled ‘Schedule - Retention Periods’;
b. No longer storing Personal Data that, despite not yet having been held for the duration of the applicable Retention Period, is inappropriate to store with regard to UK Data Protection Laws and other laws (e.g. when there is no requirement that it is retained longer for purposes such as maintaining compliant tax and employment records or dealing with legal claims);
c. Properly handling any individuals’ data erasure requests and, where appropriate, complying with such requests; and
d. Deleting or anonymising Personal Data that is no longer needed in accordance with this Policy.
Retention Periods
11. A Retention Period is a set time period after which the applicable type of Personal Data should be considered no longer needed and should be deleted or anonymised, unless a situation applies that requires certain Personal Data to be stored for longer and which justifies its further Processing (including storing) under UK Data Protection Laws. Justifications and decisions on extended storage periods can be identified and proposed by the Staff Member responsible for the applicable Personal Data, then should be approved by the data protection officer before being implemented.
12. Once Personal Data has reached the end of its Retention Period, if no justification for extension or other exception applies, this data should be deleted or anonymised in accordance with the section of this Policy titled ‘Dealing with Personal Data that is No Longer Needed’.
13. Archernar Limited’s Retention Periods are set out in the schedule to this Policy titled ‘Schedule - Retention Periods’.
14. The Retention Periods apply however the Personal Data is held by us (e.g. whatever its location or format).
Dealing with Personal Data that is No Longer Needed
15. All Personal Data that is no longer needed in any way must be either deleted (i.e. erased) or anonymised.
16. Deletion of Personal Data held electronically entails this data being permanently deleted as far as is technologically possible. This means that the Staff Member carrying out the deletion must ensure that, after deletion, it is beyond use (i.e. they must ensure that, if any traces remain, these traces cannot identify the Data Subject). To destroy any electronically held Personal Data, a Staff Member should To delete personal data, a staff member should use agreed enterprise applications to securely dispose of that data. The Staff Member carrying out the deletion should ensure that:
a. Any offline copies of the Personal Data are deleted, as well as published/online versions;
b. Any backup copies of the Personal Data are deleted, whether or not such copies are up-to-date.
17. Deletion of Personal Data held in hard copy entails destruction of this data to the extent that it is beyond use (e.g. so that it cannot be reassembled or read).
18. Anonymisation entails Personal Data being altered into a form that does not allow identification of the Data Subject in any way (i.e. so that the information no longer constitutes Personal Data and is no longer covered by UK Data Protection Laws). Anonymisation may be carried out as an alternative to deletion when useful for the Organisation and appropriate (e.g. for the purposes of carrying out statistical analysis with a large, anonymous dataset).
19. If a Staff Member needs to delete or anonymise Personal Data and they are uncertain as to how to appropriately do so, they should contact the data protection officer via email at info@archernardata.com for assistance.
Responsibility
20. Day-to-day responsibility for monitoring compliance with this Policy, for setting, evaluating, and adapting data retention practices and this Policy, and for setting, evaluating, and adapting Retention Periods, sits with the data protection officer.
21. All individuals working for or acting on behalf of Archernar Limited at all levels, including senior managers, officers, employees, consultants, trainees, homeworkers, part-time and fixed-term workers, casual workers, agency workers, volunteers, and interns (collectively ‘Staff Members’) should follow this Policy in relation to any Personal Data that they Process. If they have any questions or concerns related to this Policy and their data storage obligations, they should contact the data protection officer via email at info@archernardata.com.
Changes to the Policy and to Retention Periods
22. This Policy does not form part of any contract of employment or similar and Archernar Limited may amend it at any time at our absolute discretion.
23. Any changes to the Retention Periods will be made in compliance with the law and a new justification will be provided for each new Retention Period set. Any such changes will be communicated to relevant Staff Members in a timely manner to ensure that practices are adapted accordingly.
24. Retention Periods will be reviewed by the data protection officer (or somebody who the data protection officer has assigned to review the Retention Periods on their behalf and subject to their approval) at least once every year, to ensure that these Retention Periods are still reasonable with regard to any changes to the Personal Data held and to any new laws or guidance relevant to a given Retention Period.
Schedule - Retention Periods
Type of Personal Data
Description/
Examples
Purpose of Processing
Retention Period
Justification
Responsibility for this Type of Personal Data
prospect data
name, email, job title, phone number
To market the products and services of the company
24 months after last interaction with the company
In accordance with industry best practise and UK Data Protection law
The Data Protection Officer
customer data
name, job title, email, phone, account details
To provide services, billing and support
7 years after provision of services
For the fulfilment of contractual obligations
The Data Protection Officer
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated
28 October 2024