Full Circle Compliance understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.fullcirclecompliance.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions & Interpretation
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 or EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Full Circle Compliance, a limited company registered in England, whose registered and main trading address is Unit 12, Whitelands Business Park, Terling Road, Hatfield Peverel, Essex CM3 2AG.
Full Circle Compliance value and are committed to protecting and respecting your privacy.
This policy explains when and why we collect information about our clients, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
How do we collect information from you?
We obtain information from you from your initial contact with us either by telephone, through our website, by email, social media or in person with one of our Directors or members of staff.
What type of information is collected from you?
The information we collect may include your Name, Business Name, Address, Email address and telephone number.
How is your information used?
• We may use the information to:- Carry out the services required
• Notify you of any changes to our services (i.e. office closure times)
Lawful basis for processing of data
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever we process personal data:
The individual has given clear consent for you to process their personal data for a specific purpose. This purpose being – as set out in paragraph (1) above.
Who has access to your information?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf:
We may pass your information to our third party service providers for the purpose of completing tasks and providing services to you on our behalf (for example surveys, soil investigations, Laboratory testing).
However, when we use third party service providers, we disclose only the information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be assured that we will not release any information to third parties outside Full Circle Compliance network unless we are required to do so by law, for example, by a court
order or for the purpose of prevention of fraud or other crime.
Third Party Product Providers we work in association with:
We work closely with various third party providers to bring you a range of quality and reliable services designed to meet the needs of you, our customers. When your project requires one or more of these services, the relevant third party service provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. In some cases they will be acting as a Data Controller of your
the aim of ensuring that your privacy rights continue to be protected.
This Policy sets out the obligations of Full Circle Compliance, a company registered in United Kingdom whose registered office is at Unit 12, Whitelands Business Park, Terling Road, Hatfield Peverel, Essex CM3 2AG (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General DataProtection Regulation (“GDPR”).
The GDPR 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, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.
Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).
In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances: Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
- When the data subject withdraws their consent;
- When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
- When the personal data is processed unlawfully (i.e. in breach of the GDPR);
- When the personal data has to be erased to comply with a legal obligation; or
- Where the personal data is processed for the provision of information society services to a child.
This Policy sets out the type(s) of personal data held by the Company for Architectural and Structural Engineering Services purposes, the period(s) for which that personal data is to be retained, thecriteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.
Technical and Organisational Data Security Measures
The following technical measures are in place within the Company to protect the security of personal data. Please refer to Parts 22 to 26 of the Company’s Data Protection Policy for further details:
- All emails containing personal data must be encrypted;
- All emails containing personal data must be marked “confidential”;
- Personal data may only be transmitted over secure networks;
- Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
- Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
- Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
- Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient (or sent using Royal Mail).
- All personal data transferred physically should be transferred in a suitable container marked “confidential”;
- No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from Directors.
- All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
- No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
- Personal data must be handled with care at all times and should not be left unattended or on view;
- Computers used to view personal data must always be locked before being left unattended;
- No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise (without the formal written approval of Directors) and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
- No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR.
- All personal data stored electronically should be backed up daily with backups stored onsite. All backups should be encrypted;
- All electronic copies of personal data should be stored securely using passwords and encryption;
- All passwords used to protect personal data should be changed regularly and should must be secure.
Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
- All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available.
- No software may be installed on any Company-owned computer or device without approval; and where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Office Manager to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third- party service such as the TPS.
Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:
- Personal data stored electronically (including any and all backups thereof) shall be archived securely using the ‘put beyond use’ method.
- Special category personal data stored electronically (including any and all backups thereof) shall be archived securely using the ‘put beyond use’ method.
- Personal data stored in hardcopy form shall be shredded to at least level 3 and recycled.
- Special category personal data stored in hardcopy form shall be shredded to at least level 3 and recycled.
As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.
Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.
When establishing and/or reviewing retention periods, the following shall be taken into account:
- The objectives and requirements of the Company;
- The type of personal data in question;
- The purpose(s) for which the data in question is collected, held, and processed;
- The Company’s legal basis for collecting, holding, and processing that data;
- The category or categories of data subject to whom the data relates;
- If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.
- Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).
In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientificor historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protectt he rights and freedoms of data subjects, as required by the GDPR.
The Company’s Data Protection Officers are Kevin Craig & Ben Coleman
The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.
The Data Protection Officer shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.
Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.
Implementation of Policy
This Policy shall be deemed effective as of 25/05/2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.