The W12 Group of companies understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our employees, clients and suppliers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
W12 Group Limited (company no. 09680905) includes:
All companies are registered in England with registered offices at 4 Capricorn Centre, Cranes Farm Road, Basildon, Essex SS14 3JJ
Trading address and contact details for all companies is W12 House, 2 Chipstead Lane, Lower Kingswood, Tadworth, Surrey KT20 6RE, tel 020 7939 1913, email firstname.lastname@example.org
Your contact for all data queries is the Data Officer named in Section 16.
Some of our companies are registered as Data Controllers under the Data Protection Act 2018, as follows:
This Privacy Notice explains how we use your personal data; how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the ‘GDPR’) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in section 5 below.
Under the GDPR, you have the following rights, which we always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 16.
Further information about your rights can also be obtained from the Information Commissioner’s Office (ICO) or your local Citizen’s Advice Bureau (CAB).
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the ICO.
We may collect some or all of the following personal data (this may vary according to your relationship with us):
We collect personal data that is given to us in person and electronically. Your personal data may be obtained by mutual communication from the following examples:
We do not buy personal data from third party companies although we may be introduced to you by a third party by mutual consent.
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message, social media, post, with information, news and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
If your personal data is necessary and you fail to supply the information we need, we may not be able to enter into a contract with you, for example an employment contract, a subcontract, a sales contract.
Without relevant personal data we may not be able to engage in a relationship with you, for example, a pre-sales relationship, estimating or quoting for business, considering contracts, conducting employment interviews, etc.
Your personal data will only be stored for the original purpose for which it was gathered. However, if there is a change in purpose, for example, you change from being a subcontractor to being an employee, we will seek your permission to retain and update the data we already hold. Any change of purpose for holding data will be relevant.
We will treat your personal data with due care and respect. All personal data will be stored securely with access restricted to relevant personnel.
Computer systems will be protected by passwords, encryption and appropriate protective software. Cloud-based software holding personal data will only be used if the supplying company confirms their compliance with GDPR.
We strive to be a paperless office but where we deem necessary to keep hard copies, they will be kept in locked offices or cabinets in locked offices. Any hard copies no longer required including printed drafts of documents will be destroyed securely via a bona fide confidential shredding service or incineration on our premises.
We will not keep your personal data for any longer than is necessary in light of the reason/s for which it was first collected. Your personal data will therefore be kept for the following periods (or where there is no fixed period, the following factors will be used to determine how long it is kept):
We will only store or transfer your personal data within the European Economic Area (EEA) or countries or companies that have demonstrated their compliance with GDPR, such as the companies listed below. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
We currently store data on the following platforms ultimately based outside the EEA (whose servers are likely to be based in the United States of America):
We may sometimes contract with third parties to supply services and/or products to you on your behalf. These may include subcontractors, suppliers, business partners, business services, payment processing and marketing. In some cases those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely and in accordance with your rights, our obligations and the third party’s obligations under the law, as described in Section 12 above.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a ‘subject access request’. All subject access requests should be made in writing and sent to the email or postal address shown in Section 16.
There is not normally a charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days. Normally we aim to provide a complete response including a copy of your personal data within that time. In some cases however, particularly if your request is more complex, more time may be required up to a maximum of 3 months from the date we receive your request. You will be kept fully informed of our progress.
Electronically held data will be deleted. Printed matter will be securely destroyed via a bona fide confidential shredding service or incinerated on our premises.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we expand/reduce our group of companies, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website www.w12.group
This Privacy Notice was published on 24.05.2018