WE ARE COMMITTED TO ENSURING THAT YOUR PRIVACY IS PROTECTED. WE WILL ONLY USE THE INFORMATION THAT WE COLLECT ABOUT YOU LAWFULLY.
This privacy 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: www.landmarcsolutions.com.
The purpose of this notice 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 notice 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.
For more information regarding Landmarc Support Services and GDPR please email [email protected].
For personal information held by our Data Controller, please email [email protected].
- “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 of personal information and special Categories of personal information:
- Internal – Authenticating: Information used to authenticate an individual with something they know such as: Passwords, Pin, Mothers maiden name etc.
- Internal – Preference: Information about an individual’s preferences or interests such as: Opinions, intentions, interests, likes, dislikes, etc.
- External – Identifying: Information that uniquely or semi-uniquely identifies a specific individual such as: Name, user-name, unique identifier, pictures, biometric data etc.
- External – Ethnicity: Information that describes an individual’s origins and lineage such as: Race, national or ethnic origin, languages spoken, dialects, accents etc.
- External – Sexual: Information that describes an individual’s sexual life such as: Gender identity, preferences, proclivities, fetishes, history etc.
- External – Behavioural: Information that describes an individual’s behaviour or activity, online or offline such as: Browsing behaviour, call logs, links clicked etc.
- External – Demographic: Information that describes an individual’s characteristics shared with other such as: Age ranges, physical traits, income brackets, geographic etc.
- External – Medical and Health: Information that describes an individual’s health, medical conditions or health care such as: Physical or mental health, drug test results, disabilities, health records etc.
- External – Physical Characteristic: Information that describes an individual’s physical characteristics such as: Heights, weight, age, hair colour, skin tone, tattoos, gender etc.
- Financial – Accounts: Information that describes an individual’s financial account such as: Credit Card Number, Bank account etc.
- Financial – Ownership: Information about things an individual has owned, rented, borrowed such as: Cars, Houses, personal possessions etc.
- Financial – Transactional: Information that describes an individual’s financial account such as: Credit Card Number, Bank account etc.
- Financial – Credit: Information about an individual’s reputation with regards to money such as: Credit records, Credit rating, credit capacity, etc.
- Social – Professional: Information about an individual’s education or professional career such as: Job titles, salary, work history, school history, employment history, references, certification, disciplinary actions etc.
- Social – Criminal: Information about an individual’s criminal activity such as:Convictions, charges, criminal records etc.
- Social – Public Life: Information about an individual’s public life such as: Character, social status, marital status, religion, political affiliations etc.
- Social – Social Network: Information about an individual’s fiends and social connections such as: Friends, connections, acquaintances, group membership etc.
- Social – Family: Information about an individual’s family and relationships such as:Family structure, siblings, offspring, marriages, divorces, relationships etc.
- Social – Communication: Information communication from or to an individual such as: Telephone recordings, voice mail, email etc.
- Tracking – Computer Device: Information about a device that an individual’s user for personal information such as: IP Address, browsers history, etc.
- Tracking – Contact: Information that provides a mechanism for contacting an individual’s such as: Email Address, Physical Address, and Telephone Number etc.
- Tracking – Location: Information about an individual’s Locations such as: Country, GPS locations, building numbers, room numbers etc.
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.
Occupational Health – Landmarc Support Services are required to ensure our staff work safely. One of the ways we meet this legal obligation is through Occupational Health Screening and to facilitate this Landmarc will share specific personal information with our Occupational Health provider – PAM. For information regarding PAM’s use of personal information please see: 40d8ec_0c38804f75b34bc3815ad82e48619a6f.pdf (pamgroup.co.uk)
Landmarc Support Services are using a Legitimate interest assessment (Purpose test, Necessity test and Balancing test) to ensure that we comply with the legal basis to process personal information under the requirements of Article 6(1)(f). The assessment has been used for historical Occupational Health providers and the current provider.
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 detail 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 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.
For more information regarding Landmarc Support Services and GDPR please email [email protected].
For personal information held by our Data Controller, please email [email protected].
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.
Please refer to our Cookie Statement for more information.
DATA SECURITY AND PROTECTION
Pemco Track focuses on the highest standards of information security, privacy and transparency when using their vehicle tracking system. Pemco process data on behalf of Landmarc in compliance of GDPR procedures. Pemco have placed a high priority on protecting and managing data in accordance with the accepting standards. For more information on how Pemco manage your personal data, visit Pemco’s website or request a copy via [email protected].
Body Worn Cameras – Reveal Media
Reveal Media have designed and built a body worn video system. When using Reveal Media’s body worn video system, Reveal Media are the processors on behalf of Landmarc, acting as the controller of this information. Reveal Media take the responsibility of GDPR very strongly, for more information on how your personal data is handled visit www.revealmedia.co.uk or request a copy via [email protected].
Landmarc is certified to the following:
- ISO 9001
- ISO 14001
- OHSAS 18001
- ISO 44001
DATA PROTECTION OFFICER
We are registered with the ICO under the Data Protection Register, our registration number is Z7580556.
LANDMARC SUPPORT SERVICES COMPLIANCE STATEMENT
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 commitmentLandmarc 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.
As stated above, and as required by law, Landmarc shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed).
When establishing and/or reviewing retention periods, the following shall be taken into account:
- The objectives and requirements of Landmarc;
- The type of personal data in question;
- The purpose(s) for which the data in question is collected, held, and processed;
- Landmarc’s legal basis for collecting, holding, and processing that data;
- The category or categories of data subject to whom the data relates;
If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
Certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within Landmarc to do so (whether in response to a request by a data subject or otherwise).
In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.
Information security and 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
- 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
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 [email protected].
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.
Last modified: 06/2023
Security and Data Protection Manager