Privacy Policy
Version History
|
Date |
Version |
Reason for Change |
Author |
|
03/11/2023 |
1.0.0 |
Initial Release |
Naq |
|
06/12/2023 |
2.0.0 |
Document structure changed |
James Russell |
Privacy policy
Introduction
Benbecula Group respects the privacy of its customers, suppliers and partners. We have therefore formulated and implemented a policy on complete transparency regarding the processing of personal data, its purpose(s) and the possibilities to exercise your legal rights in the best possible way. For employees, we have formulated a separate privacy policy, available upon employment and upon request.
This privacy policy pertains to processing by Benbecula Group by means other than through the use of cookies. Benbecula Group has formulated a separate cookie policy, which can be found on our Benbecula Group’s websites: https://www.benbeculagroup.com/, https://www.tynegangway.com/, https://lift-rite.com/
Definitions
Party responsible for processing personal data: Benbecula Group; with registered address at Winconblee Road, in United Kingdom; company registration number 07038655 and Data Protection Officer James Russell who can be reached at james.russell@tynegangway.com (the “Controller”).
Data Protection Authority: The Data Protection Authority of United Kingdom. Data Protection laws:
For European citizens or residents, the EU GDPR 2018; the EU e-privacy directive 2002 (soon to be replaced by the EU e-privacy regulation);
For UK citizens or residents, the UK GDPR 2020 and the UK Data Protection Act 2018 and the national laws of the countries where we operate.
Collection of data
Your personal data will be collected by Benbecula Group and its data processors.
Personal data means any information relating to an identified or identifiable natural person (‘data subject’).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The types of personal data we may process:
|
Business process |
Type |
Data subject |
Legal basis |
|
Website |
Not applicable |
Not applicable |
Consent |
|
|
Business data, Contracts, Location, Photographs, Video |
Customers, Employees |
Legitimate interest |
|
Storage and exchange of documents |
Not applicable |
Not applicable |
Legitimate interest |
|
Delivery of goods and services |
Business data, Contracts, Photographs, Technical data (e.g. source code) |
Customers |
Performance of a contract |
|
Financial and business administration |
Business data, Contracts, Date of Birth, Educational and Employment History, Location, Photographs, Technical data (e.g. source code), Video |
Customers, Employees |
Legitimate interest |
|
Marketing |
Business data |
Customers |
Consent |
Purposes
Benbecula Group processes personal data for one or more of the following purposes: Customer, employee, contractor, partner or supplier management
Business and financial administration Direct marketing
Delivery of goods or services Work planning
How we collect, store or otherwise process your data:
The following business processes describe how we may collect, store or otherwise process the types of personal information set out in the table above:
Collection of cookies, subscription to newsletter or filling out the contact form on the website(s);
Analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our customers;
Process and respond to support requests, enquiries and complaints received from you through use of business email;
Provide services and products requested and/or purchased by you and to communicate with you about such services and/or products. We do this as necessary in order to carry out a contract with you and in accordance with our legitimate interest to operate a business;
Carry out administrative activities such as invoicing and collecting payments either locally on devices or using cloud-services;
Store and exchange personal information contained in documents through email and cloud-services; Marketing and customer acquisition through email or using cloud-services.
Sharing data with third parties
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your Personal Data outside United Kingdom. If we do, you can expect a similar degree of protection in respect of your Personal Data.
We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.
We share your personal data with the following enterprise third parties. We also share your data with SME third parties, details of which are available upon request. You will be notified when we have engaged with a new third party recipient of your personal data.
Microsoft Office 365
|
Function |
Document Storage Service |
|
Business process |
Email, Software, Tools, and Applications, Storage of Digital Documents |
|
Data categories |
Business data, Contracts, Location, Photographs, Video |
|
Data subjects |
Employees |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Adobe
|
Function |
Office |
|
Business process |
Administration |
|
Data categories |
Business data |
|
Data subjects |
Customers |
|
Physical security such as access controls, clean desk |
|
Security measures |
policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
AutoDesk
|
Function |
Document Storage Service |
|
Business process |
Storage of Digital Documents |
|
Data categories |
Business data |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
DocuSign
|
Function |
Office |
|
Business process |
Administration |
|
Data categories |
Business data |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Microsoft Office 365
|
Function |
Accountancy, CRM, Document Storage Service, Email Provider, Human Resources, Office |
|
Business process |
Administration, Business Operations, Email, Production of content, Storage of Digital Documents |
|
Data categories |
Business data, Contracts, Photographs, Video |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Google authenticator
|
Function |
User Management/Authentication |
|
Business process |
Business Operations |
|
Data categories |
Identification |
|
Data subjects |
Employees |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Dropbox
|
Function |
Office |
|
Business process |
Storage of Digital Documents |
|
Data categories |
Business data |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Indeed
|
Function |
Human Resources |
|
Business process |
Administration |
|
Data categories |
Date of Birth, Educational and Employment History, Location |
|
Data subjects |
Employees |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
|
Function |
Marketing Tool |
|
Business process |
Marketing |
|
Data categories |
Business data |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
Microsoft Sharepoint
|
Function |
Document Storage Service, Office |
|
Business process |
Administration, Business Operations, Delivery of Goods and Services, Production of content, Storage of Digital Documents |
|
Data categories |
Business data, Contracts, Photographs, Technical data (e.g. source code) |
|
Data subjects |
Customers |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
|
Function |
Office |
|
Business process |
Administration |
|
Data categories |
Business data |
|
Data subjects |
Employees |
|
Security measures |
Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods. |
International data transfers
The third parties we have engaged for the abovementioned business process may transfer your personal information to outside of your jurisdiction. Benbecula Group’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as
far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.
Where Benbecula Group transfers data to third countries, it relies on the following legal grounds for international data transfers:
An Adequacy Decision in accordance with article 45 of the GDPR
In the absence of an Adequacy Decision, appropriate safeguards in the form of Standard Contractual Clauses or Binding Corporate Rules.
In the event that Benbecula Group is reliant on Standard Contractual Clauses for the legality of its international data transfer, it ensures that the Processor or Subprocessor takes supplementary security measures to safeguard the international data transfer with one or more of the following measures:
Encryption;
Anonymisation;
Pseudonymisation.
Storage and protection of data
Your data is protected by Benbecula Group and its processors in pursuance to all legal requirements set by the relevant data processing laws. Benbecula Group has taken technical and organizational security measures to protect your data and requires its data processors to meet the same requirements. Benbecula Group has signed processing agreements with its processors to ensure an adequate level of data protection.
The following security measures are taken by Benbecula Group to protect your personal data in the course of the listed business processes:
Organisational security measures
Staff
Benbecula Group staff members are required to conduct themselves in a manner consistent with Benbecula Group’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. All staff members undergo appropriate background checks prior to hiring and sign a confidentiality agreement outlining their responsibility in protecting customer data.
We continuously train staff members on best security practices, including how to identify social hacks, phishing scams, and hackers.
Access controls
Benbecula Group maintains your data privacy by allowing only authorized individuals access to information when it is critical to complete tasks for you. Benbecula Group staff members will not process customer data without authorization.
Data hosting
As a rule, data is hosted within countries and areas that provide a substantially similar level of protection as data
subjects have under the GDPR. To ensure this, we rely on Adequacy Decisions as a legal basis for our international data transfers. In exceptional circumstances, where data is transferred to a country or area not subject to an Adequacy Decision, we rely on Standard Contractual Clauses with the recipient and take supplementary security measures to secure this data transfer, such as anonymisation.
Physical security
The data centres on which personal data is hosted are secured and monitored 24/7 and physical access to facilities is strictly limited to select staff.
Technical security measures
All devices which are used to access personal data for which we are responsible are secured with antivirus software, firewalls, encryption and access management. We regularly update operating systems and software to ensure vulnerabilities cannot be exploited.
We carry out regular vulnerability scanning of our website and have engaged credentialed external auditors to verify the adequacy of our security and privacy measures.
Your rights regarding information
Each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of their personal data, as well as the right to object to the processing and the right to data portability.You also have the right to request that you are not made subject to decision making based solely on automated processes, including profiling, if these decisions would have a significant effect on you.
You can exercise these rights by contacting us at the following email address: info@tynegangway.com. If we have any doubts as to your identity, we may request you to provide us with proof of identification, such as through sending us a copy of your valid ID. Ensure that you write “Data Request” in the subject line of your email.
Within one month of the submitted request, you will receive an answer from us. We will not charge you for submitting your request unless the request is manifestly unfounded or otherwise unreasonable in its nature. Depending on the complexity and the number of the requests this period may be extended to two months.
Marketing
You may receive commercial offers from Benbecula Group. If you do not wish to receive them (anymore), please send us an email to the following address: info@tynegangway.com and ensure that you write “Data Opt-Out” in the subject line of your email.
Your personal data will not be used by our partners for commercial purposes.
If you encounter any personal data from other data subjects while visiting our website, you are to refrain from collection, any unauthorized use or any other act that constitutes an infringement of the privacy of the data subject(s) in question. The collector is not responsible in these circumstances.
Data retention
The collected data are used and retained for the duration determined by law. You may, at any time, request your data to be deleted from any Benbecula Group account, system or other data processing medium in accordance with the process described above.
Applicable law
These conditions are governed by the laws and regulations of the country where we are headquartered. The court in the district where we are headquartered has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.
Children’s Data
We do not knowingly process children’s data, unless specifically stated in this Privacy Policy. If you have concerns about or knowledge of a child using our services, products, websites or apps without parental consent, please contact our DPO via james.russell@tynegangway.com to ensure we can take appropriate action as soon as possible.
Contact
For questions about this privacy policy, product information or information about the website itself, please contact: info@tynegangway.com.
International data transfers
Third Party Applications
Microsoft Office 365
|
Third party headquarter address |
1 Microsoft Way, Redmond, WA 98052-6399, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Microsoft Office 365 may be stored and processed in any country where Microsoft Office 365 or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Microsoft Office 365’s Privacy Policy |
Adobe
|
Third party headquarter address |
345 Park Avenue San Jose, CA 95110-2704, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Adobe may be stored and processed in any country where Adobe or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Adobe’s Privacy Policy |
https://www.adobe.com/privacy.html |
AutoDesk
|
Third party headquarter address |
The Landmark, One Market, Ste. 400, San Francisco, CA 94105, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by AutoDesk may be stored and processed in any country where AutoDesk or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see AutoDesk’s Privacy Policy |
https://www.autodesk.com/company/legal-notices- trademarks/privacy-statement |
DocuSign
|
Third party headquarter address |
221 Main Street, Suite 1550, san Fransisco, CA 94105, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by DocuSign may be stored and processed in any country where DocuSign or its affiliates, subsidiaries, or service providers operate |
|
facilities. |
|
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see DocuSign’s Privacy Policy |
https://www.docusign.com/company/privacy-policy |
Microsoft Office 365
|
Third party headquarter address |
1 Microsoft Way, Redmond, WA 98052-6399, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Microsoft Office 365 may be stored and processed in any country where Microsoft Office 365 or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Microsoft Office 365’s Privacy Policy |
Google authenticator
|
Third party headquarter address |
1600 Amphitheatre Parkway, Mountain View, CA, 94043, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Google authenticator may be stored and processed in any country where Google authenticator or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Google authenticator’s Privacy Policy |
Dropbox
|
Third party headquarter address |
333 Brannan Street San Francisco, CA 94107, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Dropbox may be stored and processed in any country where Dropbox or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Dropbox’s Privacy Policy |
https://www.dropbox.com/features/cloud- storage/cloud-security |
|
Third party headquarter address |
Sunnyvale, 1000 W Maude Ave, United States of America |
|
Personal data collected by LinkedIn may be stored and |
|
The primary location of processing is the United States of America. |
processed in any country where LinkedIn or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see LinkedIn’s Privacy Policy |
https://www.linkedin.com/legal/privacy-policy |
Microsoft Sharepoint
|
Third party headquarter address |
1 Microsoft Way, Redmond, WA 98052-6399, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Microsoft Sharepoint may be stored and processed in any country where Microsoft Sharepoint or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Microsoft Sharepoint’s Privacy Policy |
|
Third party headquarter address |
1601 Willow Rd, Menlo Park, California, 94025, United States of America |
|
The primary location of processing is the United States of America. |
Personal data collected by Whatsapp may be stored and processed in any country where Whatsapp or its affiliates, subsidiaries, or service providers operate facilities. |
|
Safeguards (art. 45 GDPR) |
Adequacy decision exists between United Kingdom and United States of America |
|
Additional safeguards |
Encryption Anonymisation where possible Pseudonymisation where possible |
|
For more information, see Whatsapp’s Privacy Policy |
https://www.whatsapp.com/legal/privacy-policy |
