We are committed to ensuring that your privacy is protected. We will only use the information that we collect about you lawfully. 

Introduction

This privacy policy notice is for the processing of personal information obtained for Landmarc’s own requirements as a Data Controller on the behalf of DIO as a Data Processor and includes the use of this website: http://www.landmarcsolutions.com/home  

The purpose of this policy is to explain to you how we control, process, handle and protect your personal information, including your rights under current laws and regulations. If you do not agree to the following policy you may wish to cease viewing / using this website. 

We are committed to safeguarding the privacy of Landmarc’s website visitors. This policy applies where we are acting as a data controller with respect to the personal data of Landmarc’s website in other words, where we determine the purposes and means of the processing of that personal data.

Policy key definitions:

• "I", "our", "us", or "we" refer to the business, [Business name & other trading names].
• "you", "the user" refer to the person(s) using this website.
• GDPR means General Data Protection Act.
• ICO means Information Commissioner's Office.
• Cookies mean small files stored on a user’s computer or device.
• "Personal data" is defined in Article 4(1) of the GDPR: "(1) '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."

Information you may provide

You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise electronic or hard formatted methods. The information you give us may include the following Categories:
• Internal: Knowledge and Belief, Authenticating, Preference
• External: Identifying, Ethnicity, Sexual, Behavioural, Demographic, Medical and Health, Physical Characteristics.
• Historical: Life History
• Financial: Account, Ownership, Transactional, Credit.
• Social: Professional, Criminal, Public Life, Family, Social Network, Communication.
• Tracking: Computer Device, Contact, Location.

Information we collect about you

With regard to each of your visits to our website we may automatically collect the following information;
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

Lawful basis for processing personal information:

• Contractual – all necessary requirements for provisioning services for you – Article 6 (1)(b)
• Legal Obligation – Statutory reporting including, financial, Health and Safety, employee and crime management purposed – Article 6 (1)(c)
• Legitimate Interests – where processing is necessary to fulfil business requirements while having a minimal privacy impact – Article 6 (1)(f)
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

The reason we use this basis

• To provide you with information about other services we offer that are similar to those that you have already enquired about;
• To ensure that content from our website is presented in the most effective manner for you and for your computer.
• Data will be retained in accordance to required regulations. 
• We process your information in the following ways:
• To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our website to ensure that content is presented in the most effective manner for you and for your computer
• As part of our efforts to keep our website safe and secure.

Sharing your information:

We may share your personal information with any member of our group, including our subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.

Where we store your personal data

Your personal data will be held securely in accordance with our internal security policy, contractual obligations and the law. If we intend to transfer your data outside the European Economic Area (EEA) we will always obtain your consent first.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.

Your individual rights

Under the GDPR your rights are as follows. You can read more about your rights in details by clicking here;
• The Right to be informed – this covers the data we hold on you and how it is processed.
• The Right of access – the GDPR Articles 1 15 and Recital 63 makes the provision to make a Subject Access Request (SAR) we will provide confirmation of data is being processed; access to their personal data; and other supplementary information. This will be provided free of charge within 1 month of proof of a valid request.
• The Right to rectification – request inaccurate personal data rectified, or completed if it is incomplete. This request can be made verbally or in writing. This will be actioned within one calendar month.
• The Right to erasure (right to be forgotten) - Individuals can make a request for erasure verbally or in writing. All requests will be actioned within one calendar month but the right is not absolute and only applies in certain circumstances.
• The Right to restrict processing - This is not an absolute right and only applies in certain circumstances. We may still store the personal data, but not use it. The request can be made verbally or in writing and we will respond within one calendar month.
• The Right to object – this includes processing based on legitimate interests or the direct marketing. 
• The Right to data Portability.
• The Rights in relation to automated decision making and profiling.

You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR. No fee required – with some exceptions you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may be charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond - We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Internet cookies

We use cookies on this website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.

Some cookies are required to enjoy and use the full functionality of this website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Most of the cookies set by visiting our website are first party cookies. These cookies are set by technologies or applications including our content management system and Google Analytics. Google Analytics provides us with statistics on how our website is being used by visitors, which pages are most visited, which are causing the most visitors to leave, as well as which search terms people used to find our website. This data helps us to provide the best possible experience for our visitors. Google Analytics does not allow us to see or record any personal information about you. 

Our website is powered by a content management system, which also sets first party cookies. If you enter details like your name and email address into our website, these cookies may remember the details entered so that when you return to our website, you don’t need to re-enter this information.

Cookies that we use are;
• Linkedin.com
• Landmarcsolutions.com
• Twitter.com
• Google-analytics.com
• Scorecardreserch.com

Data security and protection

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

Information Security

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
 
Landmarc is certified to the following:
• ISO 9001 
• ISO 14001
• OHSAS 18001
• ISO 44001

Data Protection Officer

Landmarc Support Services is not required to have a Data Protection Officer (DPO). However, we do place considerable importance on data security and privacy and therefore ensured we have a Security Team and our Data Protection and Privacy Advisor. 

We are registered with the ICO under the Data Protection Register, our registration number is Z7580556. 

Landmarc Support Services Compliance Statement

Introduction

The EU General Data Protection Regulation (“GDPR”) has come into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

This Document outlines some of the steps that we have taken in order to comply with the EU General Data Protection Regulations (GDPR)

Our Commitment

Landmarc Support Services takes Data Protection and Privacy seriously. As part of our commitment to protect the personal information of our, staff, customers, suppliers and other personals with whom we interact, we have been actively preparing for GDPR since 2017.

Our preparations have involved activity by individuals and teams within our organisation. We have approached this with a Top Down approach. In addition we have put together a new position within Landmarc, our Data Protection & Privacy Advisor is responsible for ensuring our compliance. Landmarc are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill. 

Landmarc Support Services are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Landmarc Support Services already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR Our preparation includes: -
• Information Audit – (Personal Information Inventory) carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
• Policies & Procedures - Revising/implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
• Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
• Data Retention & Erasure – we are implementing and updating our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
• Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
• International Data Transfers & Third-Party Disclosures – where Landmarc Support Services stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
• Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate. A SAR will allow a data subject to request:
o What personal data we hold about them
o The purposes of the processing
o The categories of personal data concerned
o The recipients to whom the personal data has/will be disclosed
o How long we intend to store your personal data for
o If we did not collect the data directly from them, information about the source
o The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
o The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
o The right to lodge a complaint or seek judicial remedy and who to contact in such instances
• Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met. This is documented within our Personal Information Inventory (PII).
• Privacy Notice/Policy – we have implemented and revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
• Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
• Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
• Processor Agreements – We have reviewed and updated our terms and conditions to ensure GDPR contractual requirements are met. This includes contracts between us and our customers, suppliers and subcontractors. This has been fulfilled through the use of FrameWorks Contracts, and Supply Chain Questionnaires.
• Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

Example of completed procedures include:

Personal Data Protection Principles

Relevant Procedures

Principle (a)

Data Protection Impact Assessment (DPIA)

Privacy Policy

Privacy Notice

Relevant internal Policies and Procedures

New Supplier FrameWork Contracts

Data Subject Rights

Principle (b)

Personal Information Inventory

Privacy Notice

Principle (c)

Data Protection Impact Assessment (DPIA)

Privacy Policy

Privacy Notice

Personal Information Inventory (PII)

Principle (d)

Data Protection Impact Assessment

Personal Information Inventory. (PII)

Principle (e)

Data Deletion Policy

Principle (f)

GDPR internal compliance Audit

Personal Information Inventory

Personal Management Plan

Organisational and technological measures

Commercial Agreements.

Information Security & Technical and Organisational Measures

Landmarc Support Services takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including:
• access controls
• password policy
• encryptions
• pseudonymisation
• restriction,
• IT,
• Authentication,
• IT Security: IS1 and IS2 risk treatment methodology,

Training and awareness

We are putting in place measures to ensure that individuals and teams within Landmarc Support Services are appropriately trained and aware of GDPR. We have done so by the use of “Work Place Talks” training and presentation.

Changes to this document

Any changes we make to this document in the future will be posted on this page and, where appropriate, notified to you. Please check back frequently to see any updates or changes

Contact

Questions, comments and requests regarding this should be addressed to Landmarc Support Services Ltd. Building 150, Westdown Camp, Tilshead, Salisbury, Wiltshire, SP3 4RS or by emailing dataprotection@landmarc.mod.uk.

Whistle-blowing Policy

Landmarc Support Services is committed to a free and open culture in dealings between its employees, customers, supplies and all the people with whom the Company engages in business relations. 

For more information please E-mail:
External Customers: Communications@landmarc.mod.uk
For Internal Customers: Communications@Landmarc.mod.u

Please refer to our Privacy policy for important information on the use of cookies. By continuing to use this website, you agree to this.