Your normal rights as a data subject under the Data Protection Act 2018 and GDPR apply to the data processed for the purpose stated above.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your data will be retained for the minimum period relevant to the original purpose for processing. Data submitted via the declaration form will be retained for one month. Thermal temperature camera data will only be retained where a high temperature has been recorded, and this information will be retained for one month. Once the data is no longer required it will be destroyed securely.
Access to this data will be strictly controlled and restricted to those involved in assessing the risk in relation to your access to our premises. Specifically, this will involve HR and the Operations department.
The data processed will be used to assess the risk of accessing our premises associated with the current coronavirus (COVID-19) pandemic. Specifically, the information you provide will be used as input into any decision to authorise any request to enter our premises.
This data processing is performed as a legitimate interest of us to protect the health and well-being of all members of staff and visitors to our premises.
The data relating to your health is classified as Special Category under data protection legislation. The processing of this data is performed under Article 9(2)(b) Employment under GDPR and Schedule 1 Condition 1 of GDPR.
Data processed to risk asses the access our premises by staff and visitors will be collected using a declaration form and by means of a thermal temperature detection system installed in the reception area of our premises, processing identity and Special Category (health and medical) categories of data.
If you are not satisfied with how ANON INTERNATIONAL has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing or writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time, where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:
| Purpose of processing | Retention |
|---|---|
| Client Portal accounts | 2 years from the date of last login if not proceeded to full application |
| Enquiry data obtained from third parties | 2 years from the date the enquiry was received |
After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
Your personal data may be shared with third parties for the following purposes:
| Type of recipient | Reason |
|---|---|
| Within our organisation | Depending on your requirements, it may be necessary to share your personal data within our company network and specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients |
| External suppliers | Specialist IT system providers to deliver our service to you (including sourcing of products, providing continuing advice, sharing of documentation, payment processing, informing you about relevant products and services, service & advice quality checking and improvements, and to request feedback on customer service standards). It may also be necessary to share your personal data with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to our company. |
| Licensed Credit Agencies | For the purposes of confirming your identity to comply with Anti Money Laundering requirements ( TransUnion data processing information can be found in the privacy notice on the www.callcredit.co.uk website). |
| Regulators | Sharing of information may be necessary to fulfil our legal obligations to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities. |
| Others | Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. |
These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.
We use your personal data in the following circumstances and relying on the following lawful basis for processing:
| Purpose / Activity | Type(s) of data | Lawful basis for processing |
|---|---|---|
| To initially engage with you to discuss your requirements |
|
Consent |
| To process and deliver your product |
|
Performance of a contract with you
To comply with a legal obligation Necessary for our legitimate interest (to recover debts due to us) |
To manage our client relationship with you which will include:
|
|
Performance of a contract with you
To comply with a legal obligation Necessary for our legitimate interest (to re-engage with you to review your existing product needs, and to maintain and improve customer service standards) |
| To respond to case enquiries and input to & defend against complaints |
|
To comply with a legal obligation
Necessary for our legitimate interest (to ensure that complains can be responded to accurately) |
| To perform an affordability check for a product on behalf of an Agent |
|
Necessary for our legitimate interests and of the Agent (to ensure that a product is affordable before proceeding with the purchase process) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
To comply with a legal obligation
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics and other systems including AI and automated decision-making to improve our website, products/services, marketing, customer relationships and experiences |
|
Consent/Explicit Consent
Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business, and to inform our re-engagement and marketing strategy) |
Personal data is collected by us using the following methods:
- Direct interactions with an adviser in person, by post, phone (including call recordings and voicemail), email, videoconferencing or otherwise when sourcing products and processing Identity, Contact and Financial categories of personal data.
- Automated technologies or technical interactions with our website, via the customer portal, by using the web enquiry form or processing Identity, Contact, Financial and Technical categories of personal data.
- Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:
- Agents with whom you may be interacting, but only with your consent;
- Enquiries you may perform on third-party sourcing websites.
Personal data collected, used, stored and transferred by us may include:
- Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
- Contact Data including home address, email address and telephone numbers
- Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
- Special Category Data specifically medical history
- Transaction Data including payments made for products and services you have purchased from us
- Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices used to access the website
- Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
- Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences
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