Company Name: Minttulip Limited (‘the Company’)
Company Contact details: Minttulip Limited WeWork 30 Stamford Street London SE1 9LQ
Company Representative: Kevin Moreton (SITS-Data.Compliance@sword-group.com)
Privacy notice: Privacy Notice (including for use on the company website)
Topic: Data protection
Date: 1st September 2018
Version: Rev 002
What we do
Minttulip Limited is an IT consultancy business, owned by Sword Group, which provides tangible and measurable business benefit to customers who decide to adopt Microsoft Online Technologies. Minttulip Limited must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Minttulip Limited acts as a data controller.
You may give your personal details to the Minttulip Limited directly, such as on an application or registration form or via our website. Minttulip Limited must have a legal basis for processing your personal data we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.
1. Collection and use of personal data
Purpose of processing and legal lawful basis
d.Disclosure of your personal information
2. Information to be provided when data is not collected directly from the data subject
a.Categories of data
b.Source of the personal data:
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to this privacy statement
13. Complaints or queries
2. Collection and use of personal data
a. Purpose of processing and legal lawful basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of managing our services and relationship with you and our clients (appropriate to your communication with us).
Examples of this data may include your name, address, email address, phone number, IP address, location data, your function/job title within a company along with your work email address, company name and contact details.
Uses of this personal data may include for example:-
- information requests – using contact information (from web forms, emails, mail and telephone) to send you information or provide a service;
- to carry out research about the use of our website
- Service provision where we require the collection of clients contact details to be able to provide and administer our services and to be able to monitor the quality of these services and answer enquiries;
- To deal with any complaint you might make to us
- Employee, Contractor and Job Applicant Administration – we process the personal information of our employees, contractors and job applicants to enable recruitment, remuneration, pensions, benefit management, staff administration and performance management – separate privacy Notices are available as above
If you have opted-in, we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us. Where we have had a previous commercial relationship, we will deem that you are interested in marketing information (a soft opt in).
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a lawful basis to process your personal data. The lawful bases we rely upon to offer our services to you are:
- Your consent
- Where we have a legitimate interest
- To comply with a legal obligation that we have
- To fulfil a contractual obligation that we have with you
b. Legitimate Interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
- Managing our database and keeping records up to date appropriate to the nature of your communication with us
- Providing services to you and our clients
- Contacting you to seek your consent where we need it
- Giving you information about similar products or services that you have used from us recently
- Disclosure of information relating to potential criminal acts or security threats
c. Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide our services to you.
d. Disclosure of your personal information
There are circumstances where we may wish to or have to disclose your personal data to third parties. This will only take place in line with the purposes listed above and any applicable law.
The Company will process your personal data and/or sensitive personal data with the following recipients:
- To our subsidiaries, branches or associated offices
- Any third parties who carry out audits to ensure that we run our business correctly
- Our insurers, legal advisers
- Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA
- To any other third party where you have provided your consent
3. Information to be provided when data collected not from the data subject
a. Categories of data
Personal data that we hold about you may include:-
- Name, address, email address, phone number, IP address, location data, your function/job title within a company along with your work email address, company name and contact details.
- It is unlikely that we will hold any Sensitive personal data – examples include health information and criminal convictions
b. Source of the personal data:
The Company may have sourced your personal data/sensitive personal data from
- Professional networking sites such as Linked in
- Marketing Lists
- Referrals such as from a former or current employer or colleague
- Web research
- Public information sources and third party organisations
This information (apart from referrals) came from a publicly accessible source.
4. Overseas Transfers
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
5. Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
Where the Company has obtained your consent to process your personal/sensitive data we will do so in line with our retention policy (a copy of which is available upon request). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal/sensitive data].
6. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you
- The right of access to the personal data the Company processes on you
- The right to rectification of your personal data
- The right to erasure of your personal data in certain circumstances
- The right to restrict processing of your personal data
- The right to data portability in certain circumstances
- The right to object to the processing of your personal data that was based on a public or legitimate interest
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time
Where you have consented to the Company processing your personal data/sensitive personal data you have the right to withdraw that consent at any time by contacting our Data Protection Compliance Manager at SITS-Data.Compliance@sword-group.com. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
7. Automated decision-making
We can confirm that we do not use Automated decision making processes.
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.
9. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information
10. Links to external websites
The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
11. Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
12. Data Security
The Company takes every precaution to protect our users’ information. e.g. firewalls, browser certification technology, encryption, limited access, use of passwords, two factor authentication etc.
Only employees who need the information to perform a specific job (for example, account directors, consultants, our marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. If you have any questions about the security at our website, you can email SITS-Data.Compliance@sword-group.com
13. Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
14. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact our Data Protection Compliance Manager on SITS-Data.Compliance@sword-group.com.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.