SSS privacy notice

All words with a special meaning are marked by capital letters and are as defined in the applicable data protection and privacy legislation in force from time to time in the UK including the retained EU law version of the EU GDPR, the Data Protection Act 2018 (and any associated regulations) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), as amended, and the guidance and codes of practice issued by the Information Commissioner or other relevant regulatory authority, all together called the “Data Protection Legislation”.

1.          INTRODUCTION

SSS Management Services Limited (“we”, “us”, “our”, ”SSS”) is classed as a Data Controller. This means that as well as being committed to protecting the privacy and security of your Personal Data, we are also responsible for deciding how and why we collect, hold, and use it.

We are required under the Data Protection Legislation to explain how and why we collect and use your Personal Data and are providing this Privacy Notice to explain this to you. Our website cookie policy and our monitoring policy also provide information and should be read with this Privacy Notice.

It is important that you read this Privacy Notice as it provides you with useful information that you need to know and must be provided to you under the Data Protection Legislation.  If you have any queries or if you want to raise an objection to something in this Privacy Notice, please feel free to contact us using the details below.

Email: info@sss-support.co.uk – FAO The Data Protection Officer

Postal:

The Data Protection Officer

SSS Management Services Limited

Suites 5 & 6, Fleet House
Sunderland Quay
Culpeper Close
Rochester
Kent
ME2 4HN

You are entitled to object to us processing your Personal Data, however, if you do object or fail to provide specific Personal Data when requested by us, we may not be able to provide you with the product, service or other assistance that you require.

2.          DATA PROTECTION PRINCIPLES

We will comply with the Data Protection Law and principles, which means that your Personal Data will be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about, and
• kept securely.

3.          WHAT PERSONAL DATA DO WE collect and/or HOLD ABOUT YOU?

Personal Data is any information about an individual from which that person can be identified. It does not include aggregated data or data where the identity has been removed (anonymous or pseudonymised data). There are “special categories” of more sensitive Personal Data which require a higher level of protection; however, for general website use, we do not collect this type of Personal Data which includes information 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.

Through Our Website We May Collect:

• Identity datawhich may include your first name, last name, a profile username, date of birth or your photograph or other image capturing medium;
• Contact data which may include your email address, postal address or contact telephone number;
• Technical data which may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
• Profile data which may include a username and password;
• Usage datawhich may include information about how you use our website, products and services;
• Marketing and communications data which includes your preferences in receiving marketing from us and any third parties we use, and your communication preferences.
• Aggregated data 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.

Through other sources such as careers websites or job applications, we may collect:

• Identity datawhich may include your first name, last name, a profile username, or date of birth;
• Contact data which may include your email address, postal address or contact telephone number;
• Technical data which may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
• Profile data which may include a username and password;
• Technical data which may include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
• Profile data which may include a username and password;
• Usage data which may include information about how you use our website, products and services;
• Marketing and communications data which includes your preferences in receiving marketing from us and any third parties we use, and your communication preferences.
• Aggregated data 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.
• Special Category Data which may include information 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. This may also include information about criminal convictions. We will only collect as much identifiable Special Category Data as is required by us to process any job applications and as is required by law, for security clearances or to ensure a fair application process.

4.          HOW DO WE COLLECT YOUR PERSONAL DATA?

We use different methods to collect Personal Data from and about you. These may include:

• Direct interactions with you:you may provide us with your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Visit one of our offices or sites.
• Automated technologies or interactions: as you interact with our website, we may automatically collect technical and Personal Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our cookie policyfor further details.

• Third parties, technical data or publicly available sources: we may receive Personal Data about you from various third parties such as Companies House, LinkedIn, job application sites and technical data from parties including:
• analytics providers such as Google based outside the UK or the EU; and
• search information providers such as Google based inside the UK or the EU;
• Contact and Transaction data from providers of technical, payment and delivery services based inside or outside the UK or the EU;

5.          HOW WILL WE USE your personal data?

We will only use your Personal Data when the law allows us to and for the purposes you have asked us to:

• Where we need to perform the contract, we are about to enter into or have entered into, with you;
• 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; and
• Where we need to comply with a legal or regulatory obligation.

We do not, at any time, sell or pass your Personal Data onto third parties to sell.

Purposes

• We have set out below, a description of the ways we may use your Personal Data, and which Legal Basis we rely on to do so. We have also identified what our Legitimate Interests are where appropriate. We may rely on more than one Lawful Basis for processing your Personal Data, depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one ground is used.

• 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 us. 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, however, that we may process your Personal Data without your knowledge or consent, where this is required or permitted by law.

• Third party marketing

We will get your express opt-in consent before we share your Personal Data with any company outside SSS for marketing purposes.

• Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

• Cookies

You can set your internet 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 our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

§  Automated Decision-Making

You will not be subject to decisions based solely on automated decision-making.

6.          DATA SHARING – WHO DO WE SHARE YOUR INFORMATION WITH?

We may have to share your Personal Data with the parties set out below for the purposes set out above:

• External Third Parties such as (i) professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and / or (ii) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Specific third parties such as Google; and
• 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 data transfers

 Sometimes it may be necessary to transfer some of your Personal Data to countries outside the UK or the European Economic Area (EEA). To ensure that your Personal Data receives an adequate level of protection, we implement safeguards such as standard contractual clauses, for the transfer of Personal Data as approved by the Information Commissioner’s Office and the European Commission and we also have the ability to conduct a risk assessment prior to sending any personal information to them.

7.          DATA SECURITY – HOW WILL WE KEEP YOUR Personal Data SAFE?

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, in compliance with our policies and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8.          DATA RETENTION – HOW LONG WILL YOU USE MY INFORMATION FOR?

We will only retain your Personal Data for as long as is 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 collect, hold and process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9.          WHAT RIGHTS DO YOU HAVE?

Under certain circumstances you have the right to:

• Request Access to your Personal Data (commonly known as a “subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request Correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request Erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to Processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the Restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data, for example if you want us to establish its accuracy or the reason for processing it.
• Request the Transfer of your Personal Data to another party.

If you want to exercise any of the above rights, please contact the Data Protection Officer.

10.        COMPLAINTS

While we hope that you will be happy with the way we process your Personal Data, protect your rights and manage any issues, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s supervisory authority for Data Protection issues at www.ico.org.uk or the relevant country’s Data Protection body.