Privacy Statement Policy and Procedure
Introduction
This privacy policy explains how personal data is collected and used when you use our website. It also explains how we process any data you supply to us on this website, for instance, to request a quote or use our online services.
GPS Finance is the Data Controller for any personal data that you supply to us as part of the services you are contracted to receive from us. As our client, you are our data subject.
Policy Statement
We are committed to protecting your privacy. You can access our website without giving us any information about yourself. But sometimes we do need the information to provide services that you request, and this statement of privacy explains data collection and use in those situations.
In general, you can visit our website without telling us who you are and without revealing any information about yourself. However, there may be occasions when you choose to give us personal information, for example, when you choose to contact us or request information from us. We will ask you when we need information that personally identifies you or allows us to contact you.
We collect the personal data that you may volunteer while using our services. We do not collect information about our visitors from other sources, such as public records or bodies. We do not collect or use personal data for any purpose other than that indicated below:
- To send you confirmation of requests that you have made to us.
- To send you information when you request it.
We intend to protect the quality and integrity of your personally identifiable information and we have implemented appropriate technical and GPS Finance all measures to do so. We ensure that your personal data will not be disclosed to State institutions and authorities except if required by law or other regulations.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we don’t have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.
Our Address is 228 Church Lane, Kingsbury NW9 8SN
Telephone: 0203 4894747
Email: Support @gpsfinance.co.uk
GPS Finance has a Data Protection Officer who can be contacted at 228 Church Lane, Kingsbury NW9 8SN.
What personal data do we collect?
We will obtain personal data about you (such as your name, address, email address, telephone number) whenever you complete an online form. For example, we will obtain your personal data when you register to use the Site, send us feedback, post material, contact us for any reason, sign up to a service, enter a competition, purchase goods or services, or as part of the provision of your existing contractual services
We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs, and other communication data whether required for billing purposes or otherwise, the originating domain name of a user’s internet service provider, IP address, operating system, browser type. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on ‘Use of cookies’ below.
Occasionally we may receive information about you from other sources (such as credit reference agencies) which we will add to the information which we already hold about you to help us provide goods and services.
What we do with your personal data
We will use your personal data for any one or more of the following purposes: To help us identify you and any accounts you hold with us; administration; research, statistical analysis, and behavioral analysis; customer profiling and analyzing your purchasing preferences; marketing—see ‘Marketing and opting out’ below; fraud prevention and detection; to prevent and/or detect crime; billing and order fulfillment; credit scoring and credit checking—see ‘Credit checking’ below; customizing this Site and its content to your particular preferences; to notify you of any changes to this Site or to our goods and services which may affect you; improving our goods and services; to allow you to participate in interactive features of the Site; in the event, we sell or buy any business or assets.
The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.
What we do |
Our legal basis under GDPR |
|---|---|
| Use the personal data that you provide on our web forms and questionnaires | Article 6(1)(b) – when you provide us with your personal data, for instance, to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract |
| Provide goods and services to you | Article 6(1)(b) – this is necessary for the performance of a contract with you, our data subject |
| Provide our online services | Article 6(1)(b) – this is necessary for the performance of a contract with you, our data subject |
| Contact you regarding the services we provide | Article 6(1)(f) – we need to contact you for our legitimate interests so that we can gather more information for the provision of our services, or to deliver those services most effectively |
| Retain your data under our data retention policy after your contract has expired | Article 6(1)(f) – we need to retain your personal data for only as long as necessary under the law to protect our legitimate interests |
| Where you require us to make Reasonable Adjustments to enable you to attend a meeting or interview, we may require further information from you. | Article 9(2)(a) of GDPR (explicit consent). |
If this includes information about your physical or mental health, such information (being sensitive personal data, Special Category data), will only be used by us, with your explicit consent, to assess your eligibility for Reasonable Adjustments. We will not share or disclose it to others. You can withdraw your consent at any time by contacting us. Please note that we may not be able to process your request for Reasonable Adjustments if you do this.
The following table sets out the categories of personal data that we obtain.
Personal Data |
Explanation |
|---|---|
| Name, postal address, email address, website, identification number, location data, online identifier – these are classed as personal data | This data is provided by you on our web forms and questionnaires when you register to use the Site, send us feedback, post material, contact us for any reason, sign up to a service, enter a competition, purchase goods or services, or as part of the provision of your existing contractual services. This data may be provided if you apply for a job opportunity. |
We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email inquiries; notify you of any upcoming marketing, training, or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues; provide you or your GPS Finance with advice and determine suitability for employment.
We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent, unless otherwise authorized, required, or permitted under the laws of England and Wales. GPS Finance does not sell your data to third parties.
If you no longer wish to receive information about our services, please send an email to our GPS Finance Data Protection and Compliance Officer at support @gpsfinance.co.uk advising that you do not wish to receive further information.
Will we disclose your data?
Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial or administrative services in connection with the operation of our business; and to any person (where necessary) in connection with their services, such as law enforcement, regulatory authorities, partners or advisors within the UK.
The handling of these operations is governed by a data processing contract between us and our external service provider, ensuring a commitment to the principals of the GDPR and the Data Protection Act 2018. We ensure external service providers are only authorised to use personal data for the limited purposes specified in our agreement with them.
GPS Finance implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
Availability
GPS Finance utilises the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacentre level disasters. All failover mechanisms are fully automated.
No personal data is stored permanently outside GPS Finance’s cloud platforms. The physical security is thereby maintained by GPS Finance’s subcontractors, see clause 7. Microsoft’s datacentres comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
Integrity
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft datacentres and within datacentres themselves.
Confidentiality
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
Whenever personal data is accessed by authorised personnel, the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
Any device being used to access personal data is login protected by GPS Finance Directory , Microsoft’s cloud based identity and access management service, and has GPS Finance corporate antivirus solution installed. If any personal data are temporarily stored on a device, the storage unit on the device must also be strongly encrypted.
On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
Transparency
GPS Finance will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. GPS Finance will also provide the summaries of any independent audits of the Service.
Isolation
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. GPS Finance ‘s Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.
How long we keep your personal data
Personal data from our data subjects is retained in line with our data retention policy. GPS Finance keeps most data for 7 years, which covers the 6 years by law in which we have to keep certain information for a minimum of 6 years plus the current year. Personal data that is no longer necessary to be kept under GPS Financedata retention policy will be deleted. Under GPS Finance data retention policy, there are certain exemptions in relation to financial data and health data. A copy of GPS Finance data retention policy can be made available upon request.
Your Rights
You have the following rights in relation to personal data held on you by GPS Finance:
- The right to be informed about how personal data is used – (this notice)
- The right to access a copy of personal data that GPS Finance holds about you
- The right to rectification of any errors in personal data held by GPS Finance
- The right to erasure of any personal data
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision-making including profiling
If you wish to learn more about these rights and how they operate, please look at the ICO’s website https://ico.org.uk/for-the-public/.
GPS Finance does not operate any automated decision-making systems.
You have a right to request a copy of the personal data that we hold about you. If you would like a copy of some or all of your personal data, please email support@gpsfinance.co.ukor write to our GPS Health Online Data Protection and Compliance Officer at 228 Church Lane, Kingsbury NW9 8SN Proof of your identity will be required for security purposes.
If you are unhappy with the response that you receive from us when you exercise your GDPR rights or Data Protection Act 2018 rights, you have the right to lodge a complaint to the ICO. More guidance about raising a complaint with us is available on the ICO’s website https://ico.org.uk/for-the-public/raising-concerns/ and for raising a complaint with the ICO, more information is available on https://ico.org.uk/concerns/.
Personal Data breach notification
In the event that your data is compromised, we will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and GPS Finance action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
Other websites
Our website may contain links to other sites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policy.
Monitoring
GPS Financeuses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made. System performance and availability is monitored from both internal and external monitoring services.
How to contact us
Please review the website regularly as this statement may change from time to time. If you have any questions about our privacy policy or information, we hold about you please contact:
GPS Finance Data Protection and Compliance Officer
Telephone: 02034894747
Email: support@gpsfinance.co.uk
