Introduction
As part of our sales process, the Company collects and processes personal information, or personal data, relating to sales enquiries. This personal information may be held by the Company on paper or in electronic format.
The Company has appointed a compliance officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact us on: info@transcosmos.co.uk +44 (0)1280 824331 transcosmos Information Systems Ltd, Challenge House, Sherwood drive, Bletchley, MK3 6DP.
Data protection principles
Under the GDPR, there are six data protection principles that the Company must comply with. These provide that the personal information we hold about you must be:
The Company is responsible for, and must be able to demonstrate compliance with, these principles. This is called the principle of accountability.
What types of personal information do we collect about you?
Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed. There are also “special categories” of personal information, and personal information on criminal convictions and offences, which requires a higher level of protection because it is of a more sensitive nature. The special categories of personal information comprise information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
The Company collects, uses and processes a range of personal information about you during the sales enquiry process. This includes (as applicable):
How do we collect your personal information?
The Company collects personal information about you during the sales enquiry process, either directly from you or sometimes from a third-party site such as Linked in or similar.
Your personal information may be stored in different places, including our sales transaction tool, and in other IT systems, such as the e-mail system.
Why and how do we use your personal information?
We will only use your personal information when the law allows us to. These are known as the legal bases for processing. We will use your personal information in one or more of the following circumstances:
We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to take steps at your request to enter into a contract with you/your company, or to enter into a contract with you/your company, and to enable us to comply with our legal obligations. In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include: pursuing our business by expanding or initialising new services; managing the sales process and performing effective internal administration.
The purposes for which we are processing, or will process, your personal information are to:
What if you fail to provide personal information?
If you fail to provide certain personal information when requested, we may not be able to process your sales enquiry properly or at all, we may not be able to enter into a contract with you/your company.
Change of purpose
We will only use your personal information for the purposes for which we collected it, i.e. for the sales enquiry process.
Who has access to your personal information?
Your personal information may be shared internally within the Company for the purposes of the sales enquiry, including with other members of the Sales and Commercial Department, members of the recruitment team, and senior members of the service management team.
The Company uses a third-party provider “Pipedrive” to process all sales enquiries, and personal data maybe subject to external audits of multiple kinds (e.i. ISO 9001). The Company uses a third-party website operator to collect contact details of those website visitors who submits their email address on the “Case Studies” or the “Contact us” page. We will not share your personal information with any other third parties during the sales enquiry process.
How does the Company protect your personal information?
The Company has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. You can obtain further information about these measures from our Sales and Commercial Department.
Where your personal information is shared with third parties, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes unless they will become controllers of your personal data on their own right.
The Company also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other competent supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
For how long does the Company keep your personal information?
The Company will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.
If the sales enquiry process you are involved in results in no business contract entered in to, the Company will generally hold your personal information for twelve months after the end of the relevant sales enquiry exercise but this is subject to: (a) any minimum statutory or other legal requirements for particular data or records, and (b) the retention of some types of personal information for up to six years to protect against legal risk.
If the sales enquiry process you are involved in results in a business contract entered in to, personal information gathered during the sales enquiry process will be retained for the duration of the contract and for a further six years to protect against legal risk, and in accordance with the privacy notice for external companies.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
In some circumstances we may anonymise your personal information so that it no longer permits your identification. In this case, we may retain such information for a longer period.
Your rights in connection with your personal information
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
If you wish to exercise any of these rights, please contact our Sales and Commercial Department. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our Sales and Commercial Department. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to a supervisory authority. You may raise a complaint with any of the supervisory authorities depending on where you live, work, or the alleged infringement took place at any time.
Transferring personal information outside the European Economic Area
The Company may transfer your personal information to countries outside the European Economic Area (EEA) currently the Philippines. There is not an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your personal information is not deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal information does receive an adequate level of protection, it is transferred outside the EEA on the basis of the following safeguard: Only limited and restricted authority will be given to those whose jobs require access to your data or other information e.g.; Sales and Commercial Department, members of the recruitment team, and senior members of the service management team. Anyone found to misuse or disclosed sensitive information will be dealt with in accordance with the company’s disciplinary policy and procedure. Breeches will normally be treated as gross misconduct, and the absence of mitigating circumstances, will result in summary dismissal. You can obtain further information about these measures from our Human Resources Department
Automated decision making
Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention.
We do not envisage that any sales enquiry processes will involve the use of automated decision making.
Changes to this privacy notice
The Company reserves the right to update or amend this privacy notice at any time.
Contact
If you have any questions about this privacy notice or how we handle your personal information, please contact us as follows: info@transcosmos.co.uk +44 (0)1280 824331 transcosmos Information Systems Ltd, Challenge House, Sherwood drive, Bletchley, MK3 6DP.
Use of Cookies by transcosmos
Cookies 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. The table below explains the cookies we use and why.
How do I manage my cookie settings?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
We are planning to enhance our cookie tool to allow users to more easily change their cookie settings after their initial choice.