GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
[Surface Web Media Ltd] (“We”) are committed to protecting and respecting your privacy.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
[SAMANTHA ELLEN] is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: [ACCOUNTS@SURFACEWEBMEDIA.COM].
For all data matters contact [SAMANTHA ELLEN] on [ACCOUNTS@SURFACEWEBMEDIA.COM].
3. The purpose(s) of processing your personal data We use your personal data for the following purposes:
[Contact you in connection with services provided and respond to requests you made to us to provide any information. Keeping your information secure at all times.]
4. The categories of personal data concerned with reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data [Name, Address, Telephone & email.]
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Consent of the data subject; *INCLUDE A GDPR CONSENT FORM
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Processing necessary for compliance with a legal obligation
Processing necessary to protect the vital interests of a data subject or another person
Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
b) Special categories of personal data (article 9 of GDPR)
[*IF YOU PROCESS SPECIAL CATEGORIES OF DATA, YOU MUST SATISFY AT LEAST ONE CONDITION UNDER ARTICLE 6 AND AT LEAST ONE CONDITION UNDER ARTICLE 9 AS LISTED BELOW. DELETE
THIS SECTION IF YOU DO NOT PROCESS SPECIAL CATEGORIES OF DATA.]
Our lawful basis for processing your special categories of data:
Explicit consent of the data subject [INCLUDE THE GDPR: CONSENT FORM]
Processing necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement
Processing necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent
Processing carried out by a not-for-profit body with a political, philosophical, religious or trade union aim provided that the processing relates
only to members or former members (or those who have regular contact with it in connection with those purposes); and there is no disclosure to a third party without consent
Processing relates to personal data manifestly made public by the data subject
Processing necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity
Processing necessary for reasons of substantial public interest on the basis of EU or Member State law
Processing necessary for reasons of
preventative or occupational medicine, for assessing the working capacity of an employee. medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional
Processing necessary for the reasons of public interest in the area of public health
Processing necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data Your personal data will be treated as strictly confidential.
How long do we keep your personal data?
[We keep your personal data for no longer than reasonably necessary for a period of [48 MONTHS] in order to [FULFIL OUR CONTRACTUAL AGREEMENTS]. Examples include: in case of any legal claims/complaints; for safeguarding purposes etc.]
7. Providing us with your personal data
[We require your personal data as it is a requirement necessary to enter into a contract and for us to do the necessary work] If you fail to adhere the consequences will be [breaching the terms of contract].
8. Your rights and your personal data
Unless subject to an exemption under the GDPR, 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 YOUR LAWFUL BASIS FOR PROCESSING THE 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 i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the 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 the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
9. Transfer of Data Abroad [WE DO NOT TRANSFER PERSONAL DATA OUTSIDE THE EEA.]
10. Automated Decision Making [WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.]
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then
we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
12. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our [DATA PROTECTION OFFICER/OUR DATA REPRESENTATIVE] on [ACCOUNTS@SURFACEWEBMEDIA.COM].