GDPR: Data Privacy Notice for Clients & Suppliers
Introduction
Halo Support ("We") are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
1. Definitions
Data controller:
A controller determines the purposes and means of processing personal data.
Data processor:
A processor is responsible for processing personal data on behalf of a controller.
Data subject:
Natural person
Categories of data:
Personal data and special categories of personal data
Personal data:
The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data:
The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing:
Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party:
Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Halo Support Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Halo Support Ltd, 40 Brondeg, Heolgerrig, Merthyr Tydfil. CF48 1TW, 07446 975496, info@halo.support.
For all data matters contact Tom Lewis on 07446 975496, info@halo.support
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
Sign in System
To create your electronic Sign in System in order for it to be delivered to you with the required information such as staff names and email addresses pre-filled.
For more information on exactly how the Sign-in System handles and secures information please see the separate document “Halo Sign-in System Data Handling Document” which will have been supplied to you or is available upon request.
Support or Training Contract
Providing ICT services to you in line with any contract you have in place with us.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data:
Email address
Full Name and Title
Job Title/Position within the organisation
We have obtained your personal data from your organisation at the point of commencing a working relationship with us for the purposes of supplying you with an electronic Sign-in System and/or ICT services.
Throughout the use of your Sign-in System you may contact us for support and when necessary we may ask you to send a copy of your Application to us for technical reasons such as providing support or updates. During this time we would be able to access information held on the system which would include any data you have collected on individuals. Unless there is a specific need to access any of this data, for example, to investigate a specific issue then we will not access or read any information held within the Application.
5. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
| ☐ Consent of the data subject; | *include a gdpr consent form |
| ✓ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract | ICT Support Service or Sign-in System |
| ☐ Processing necessary for compliance with a legal obligation | |
| ☐ Processing necessary to protect the vital interests of a data subject or another person | |
| ☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller | |
| ☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject |
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with:
Tom Lewis and Mark Haycock - Co-Founders of Halo Support Ltd
Third-party companies as requested by yourself i.e. Google (If setting up Google Workspace), Apple (If setting up iPads) – Any requests of this nature will require written permission from you (email format will be accepted)
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary or for the duration of your ICT Support Service with us in order to provide the services purchased.
8. Providing us with your personal data
We require your personal data as it is a contractual requirement.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
It is sometimes necessary for us to transfer data to countries outside of the EEA. Whenever we transfer data outside of the EEA we take all steps possible to ensure that the company storing the data complies with data processing practices such as the EU-US Privacy Shield Framework.
Regarding the Halo Sign-in System, the data is stored on the iPad itself, not on a server controlled by Halo or in the “Cloud”. When emailing data from the Halo Sign-in System it is possible that the data could be stored outside of the UK depending on the email account used to send or receive that data.
For example, using a Google email address to send data to a company-controlled email may mean that the “sent” email is stored on a Google server that is located outside of the UK.
11. Automated Decision-Making
WE DO NOT USE ANY FORM OF AUTOMATED DECISION-MAKING IN OUR BUSINESS.
12. Further Processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be notified to you by e-mail.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Tom Lewis on 07446 975496, info@halo.support
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
If you need to contact us via mail:
Halo Support Ltd.
40 Brondeg
Heolgerrig
Merthyr Tydfil
CF48 1TW