EXCHANGE COMMUNICATIONS (UK) LTD
CUSTOMER PRIVACY NOTICE
Exchange Communications Group Ltd (“Exchange”) collects and processes personal data relating to its clients in order to provide telecommunications services. Exchange is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. Reference is also made to Exchange’s Data Protection Policy.
1. What information does Exchange collect?
Exchange collects and processes a range of information containing personal data about you. This may include the following:
- your name, address and contact details, including email address and telephone number, your occupation and employer.
- where you are a sub-contractor on-site, your National Insurance number and next of kin contact information.
Where you are a sub-contractor, we may also collect, store and use the following special category data (more sensitive personal information) from you as follows:
- information about any welfare, health and safety incidents and security incidents.
Exchange may collect this information in a variety of ways including directly from you or from your employer.
Your personal data will be stored on Exchange’s IT system.
2. Why does Exchange process your personal data?
Where you are an individual, sole trader or partner in a partnership which has contracted with Exchange, Exchange needs to process data in order to meet its obligations and exercise its rights in terms of that contract.
In other cases, Exchange has a legitimate interest in processing personal data which allows Exchange to:
- meet its obligations and exercise its rights in terms of a contract to which you are not party but where you have been involved in the negotiations, conclusion or implementation of a contract for provision of services by Exchange
- where you are employed or contracted by a sub-contractor engaged by Exchange and for whom Exchange has responsibility for while on site
Some special categories of personal data, such as information about health or medical conditions, are processed by Exchange to carry out its obligations such as those in relation to health and safety law.
There may be some occasions where we seek your consent to process personal data but in this case we will provide full details of what we are seeking consent for, so that you will be able to carefully consider whether to provide that consent.
3. Who has access to data?
Your information may be shared internally as appropriate, including with members of the business area relevant to the services which Exchange is to provide or the activities undertaken. Your information may also be also be shared with other “Exchange” companies:- Exchange Communications Group Ltd; Exchange Communications Installations Ltd and Exchange Communications Support Ltd
We will also share your data as required by law to administer the working relationship that we have with you.
Exchange also shares your data with third parties, including sub-contractors engaged by Exchange to provide telecommunications services on behalf of Exchange and third party service providers that process data on its behalf in connection with invoicing services and IT services (including Walker Information Inc.
Exchange may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.
4. How does Exchange protect data?
Exchange takes the security of your data seriously. Exchange has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Where Exchange engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. They are also not allowed to use your personal data for their own purposes.
5. How long does Exchange keep your data?
Exchange will hold your personal data for the duration of any contract with you and for a fixed period thereafter. The periods for which your data is held after the end of the contract and in all other situations are set out in Exchange’s Data Retention Policy.
6. Your rights
As a data subject, you have a number of rights. Please refer to Exchange’s Data Protection Policy/Data Subject Rights Policies for further details of these rights:-
- access and to obtain a copy of your data on request;
- require Exchange to change incorrect or incomplete data;
- require Exchange to delete or stop processing your data, in certain circumstances;
- object to the processing of your data where Exchange is relying on its legitimate interests as the legal ground for processing;
- portability; and
- right to object to automated decision making.
If you would like to exercise any of these rights, or if you have any concerns about how your personal data us being processed, please contact firstname.lastname@example.org
If you believe that Exchange has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details are available at www.ico.org.uk
7. What if you do not provide personal data?
Where you have entered into a contract with Exchange for provision of services, failing to provide the data may mean that Exchange is unable to properly implement the contract and that you are unable to exercise certain contractual rights.