The privacy of our customers’, suppliers’ and employees’ personal data is important to Armorgard Ltd. Guarding that privacy is something we take very seriously. We have taken steps to ensure all data is kept secure throughout all past, present and future processes. Armorgard Ltd is committed to being transparent about how it collects and uses the personal data and to meeting our data protection obligations.
Armorgard has given our Human Resources Manager the responsibility for data protection compliance within the organisation. They can be contacted at email@example.com. Questions about this policy, or requests for further information should be directed to them.
Armorgard is a leading manufacturer of security and safety products. We offer a wide range of solutions, predominately for the construction industry. We sell our products through a network of distributors. In order to meet our customers’ needs and to carry out our business operations, we sometimes need to gather personal data. The following information explains what data we collect, how we use and store it, and how you can control the data.
These definitions and interpretations apply to the content of this policy:
Personal Data - is any information that relates to a living individual who can be identified from that information
Processing - is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
Data protection principles
Armorgard Ltd processes personal data in accordance with the following data protection principles:
Armorgard processes personal data lawfully, fairly and in a transparent manner
Armorgard collects personal data only for specified, explicit and legitimate purposes
Armorgard processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing
Armorgard keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay
Armorgard keeps personal data only for the period necessary for processing
Armorgard adopts appropriate measures to make sure that personal data is secure and protected against unauthorised or unlawful processing and accidental loss, destruction or damage.
Personal data we collect
We collect data in order to operate effectively, and to provide you with the best experience in relation to our products and services. The information we collect includes the following:
- Name and contact data
We collect first and last name, email address, postal address, phone numbers.
- Payment data
We collect data necessary to process your payment if you make purchases, such as bank details, credit card details and security codes associated with your payment
- IP address and cookies
- Employee data
In addition to name, contact and payment data, we also collect birth date, NI Number, NOK and medical arrangements for contractual purposes.
This data enables us to carry out all transactions efficiently. Therefore, we process data as the Data Controller.
This information is taken directly from you, the individual, via phone, face-to-face interaction, or via our website enquiry form and is stored on our secure client relationship management (CRM) or enterprise resource planning (ERP) system.
There are times where we receive and process personal data on behalf of our customers. For example, we may be given personal details by our customers (distributors) so that our products can be delivered to their end user. Here we abide by the terms set out in our third-party agreement as a Data Processor.
How we use personal data
Armorgard uses this data to process orders, manage your account and - if you agree - to email you about other products and services we think may be of interest to you. In processing your order, we may need to send some of your personal details to third parties such as hauliers and credit reference agencies to ensure efficient transactions. All third parties are monitored through Third Party Agreements.
All personal data will be processed with consent or on the grounds of legitimate interests. Where consent is required, we shall obtain it directly from you. Where we have a legitimate interest in processing data (for example where we need to do so to supply our products and process orders) we shall do so but will always make it easy for you to opt-out of communications.
How we store your data
All personal data is stored securely on our CRM and/or ERP system. These systems have restricted access and are password protected. Any hard copy detailing personal data is filed and locked securely in an office with restricted access and securely shredded when appropriate. We store this data as long as is necessary. For example, data required for HMRC purposes is retained for 7 years. All personal data is removed from account information on the systems after 18 months of inactive use. For more information on our retention and storage of information, please refer to our Data Retention Policy
As a data subject, you have a number of rights in relation to your personal data.
Subject access rights
You have the right to make a subject access request. If you choose to do so, Armorgard will let you know:
Whether or not your data is processed and if so why; the categories of personal data concerned; and the source of data if it is not collected directly from you
To whom your data is, or may be disclosed, including recipients located outside of the European Economic Area (EEA) and the safeguards that apply to such transfers
For how long your personal data is stored (or how that period is decided)
Of your rights to rectify or erase data, or to restrict or object to processing
Of your rights to complain to the Information Commissioner if you think Armorgard Ltd has failed to comply with your data protection rights
Whether or not Armorgard Ltd carries out automated decision making and the logic involved to any such decision making
Armorgard Ltd will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made the request electronically, unless you agree otherwise. In some cases, we may ask you for proof of identification before the request can be processed. We shall inform you if you need to verify your identity and will tell you which documents we require.
To make a subject access request, please email or write to us at the following:
firstname.lastname@example.org (Human Resources Department)
c/o Human Resources
Unit 14 – 16 Fareham Industrial Park
Armorgard Ltd will normally respond to a request within one month from the date it is received. In some cases, such as where we process large amounts of individuals data, we may respond within three months of the date the request is received. Armorgard will write to you within one month of receiving the original request to inform you if this is the case.
If a subject access request is manifestly unfounded or excessive, Armorgard Ltd is not obliged to comply with it. Alternatively, Armorgard can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which Armorgard has already responded. If you submit a request that is unfounded or excessive, the organisation will notify you that this is the case and inform you of whether or not we will respond to it.
Other Individual rights
Individuals also have a number of other rights in relation to their personal data. You can ask Armorgard to:
Rectify inaccurate data
Stop processing or erase data that is no longer necessary for the purposes of processing
Stop processing or erase data if your interests override Armorgard’s legitimate grounds for processing data (where Armorgard relies on its legitimate interests as a reason for processing data)
Stop processing or erase data if processing is unlawful and
Stop processing data for a period if data is inaccurate or if there is a dispute about whether or not your interest overrides Armorgard’s legitimate grounds for processing data.
To ask Armorgard to take any of these steps, please send your request to email@example.com (Human Resources Department).
Armorgard Ltd takes security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure and to ensure that data is not accessed, except by employees in the proper performance of their duties.
Where Armorgard engages with third parties to process personal data on our behalf, such parties do so on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure security of data. This is documented in third party agreements.
Some of the processing Armorgard carries out may result in risks to privacy. Where processing would result in a high risk to individuals rights and freedoms, Armorgard will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
If Armorgard discovers that there has been a data breach of personal data that poses a risk to the rights and freedoms of individuals, we shall report it to the Information Commissioner’s Office (ICO) within 72 hours of discovery. Armorgard will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we shall tell the affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures we have taken.
Employee access and training
Employees may have access to personal data of our customers and clients in the course of their employment/contract. Where this is the case, Armorgard relies on employees to help meet its data protection obligations to all concerned.
Employees that have access to customer/client personal data are required:
To access only data that they have authority to access and only for authorised purposes
Not to disclose data except to individuals who have appropriate authorisation
To keep data secure (for example by complying with rules on access to premises, computer access, including password protection and secure file storage and destruction)
Not to remove personal data or devices containing or that can be used to access personal data, from the organisations premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and device
Not to store personal data on local drives or on personal devices that are used for work purposes; and
To report data breaches of which they become aware to Human Resources immediately.
Armorgard will provide training to all employees about their data protection responsibilities as part of their induction process and at regular intervals thereafter.
We would like to send you information about Armorgard products and associated services that we think may be of interest to you. If you have given consent to receive this kind of correspondence, you may opt-out quickly and easily at any time.
You have the right to stop us from contacting you for marketing purposes or from giving your information to other third parties.
If you no longer wish to be contacted for marketing purposes, please contact firstname.lastname@example.org
How to contact us
Or write to us at Armorgard Ltd, c/o Human Resources, Unit 14-16 Fareham Industrial Park, Standard Way, Fareham, Hants, PO16 8XB