This Policy sets out the obligations of DVAD (“the Company”) regarding data protection and the rights of customers, team members and business contacts (“data subjects”) in respect of their personal data under the General Data Protection Regulation (“the Regulation”).
The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly.
The Company is committed to upholding the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU.
Who We Are
DVAD have been offering Business Telephone Systems and Communications Solutions for over 30 years and are one of the most respected companies in the UK.
DVAD uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which we believe may be of interest to you and your business. In you making initial contact you consent to us maintaining a promotional dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. DVAD also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, DVAD will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from exhibitions, workshops, seminars, webinars and roadshow events, including the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our different websites, including but not limited to personally identifying information like Internet Protocol (IP) addresses. DVAD may from time to time use such information to identify its visitors. DVAD may also collect statistics about the behaviour of visitors to its website.
Any information we hold about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.
We will only collect the information needed so that it can provide you with marketing services, the business does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that DVAD has purchased from a third-party list broker, on behalf of a client.
Legal basis for processing any personal data.
To meet our contractual obligations to clients and to also respond to marketing enquiries.
Through agreeing to this privacy statement, you are consenting to us processing your personal data for the purposes outlined. You can withdraw consent at any time by Telephone, contacting us by email or writing to us.
DVAD may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. DVAD requires these parties to agree to process this information based on our instructions and requirements consistent with this privacy statement and GDPR. DVAD does not broker or pass on information gained from your engagement with the agency without your consent. However, DVAD may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of DVAD, its clients and/or the wider community.
DVAD will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.
Personal data is held in the EEA using different servers. Some personal data is held outside the EEA in the US using different platforms such as Google Drive and different social media solutions. Each provider is a signature to the EU/US Privacy Shield. Where data is held in countries outside the EEA where possible we will always first check that the supplier has data compliance certification.
Your Rights As A Data Subject
At any point whilst we are in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that we refuse your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
DVAD at your request can confirm what information it holds about you and how it is processed.
You Can Request The Following Information
- Identify the contact details of the person or organisation (DVAD)
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of DVAD or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Gain Access To The Personal Data We Hold
To gain access to the personal data we hold, identification will be required. DVAD will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If we are dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made by phoning 0800 84 999 84 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by us or our partners, you have the right to complain to our DPO. If you do not get a response within 30 days you can complain to the ICO quoting our ref number Z7923920.