1.1 We are committed to safeguarding the privacy of our website visitors; in this policy, we explain how we will treat your personal information.
2.1 Ci5 Security™ is a trading name of Ci5 Security Group Ltd registered company number 10856596, registered with the ico number ZA265693
3.1 We may collect, store and use the following kinds of personal information and you agree to using or submitting details:
(a) Information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths.
(b) Information that you provide to us when registering with our website including your email address.
(c) Information that you provide when completing your profile or applying for work using our join us form on our website including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details, five-year job history, references that we take up.
(d) Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters including your name and email address.
(e) Information that you provide to us when using the services on our website, or that is generated in the course of the use of those services including the timing, frequency and pattern of service use.
(f) Information relating to any purchases you make of our goods or, and services or any other transactions that you enter through our website including your name, address, telephone number, email address and any credit or debit card details.
(g) Information that you or we post to our website for publication on the internet including your user name, your profile pictures and the content of our / your posts.
(h) Information contained in or relating to any communication that you send to us or send through our website including the communication content and metadata associated with the communication and using any live chat powered by (tawk.t) feature we have installed that you may use to communicate with us.
(i) Any other personal information that you choose to send to us.
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) Administer our website and business
(b) Personalize our website for you
(c) Enable your use of the services available on our website
(d) Send you goods purchased through our website
(e) Supply to you services purchased through our website
(f) Send statements, invoices and payment reminders to you, and collect payments from you
(g) Send you non-marketing commercial communications
(h) Send you email notifications that you have specifically requested
(i) Send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter or Marketing as well as using the unsubscribe link
(j) Send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications) firstname.lastname@example.org
(k) Provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information
(l) Deal with enquiries and complaints made by or about you relating to our website
(m) Keep our website secure and prevent fraud and
(n) Verify compliance with the terms and conditions governing the use of our website including monitoring private messages sent through our website private messaging service
4.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
5.1 We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information].
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].
6.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
6.4 You expressly agree to the transfers of personal information described in this Section 6.
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Without prejudice to Section 7.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
(a) personal data type will be deleted after to the extent that we are required to do so by law
7.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
8.3 All electronic financial transactions entered into through our website will be protected by encryption technology.
8.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
9.1 We may update this policy from time to time by publishing an updated version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2 We may withhold personal information that you request to the extent permitted by law.
10.3 You may instruct us at any time not to process your personal information for marketing purposes.
10.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.5 We use both session and persistent cookies on our website.
13.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
(a) we use [cookie name] to recognize a computer when a user visits our website and to track users as they navigate the website or enable the use of a shopping cart on the website or to improve the website’s usability and to administer the website or to prevent fraud and improve the security of the website and personalize the website for each user to validate authenticated users sessions, facilitate the use of our website search engine.
13.7 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
13.8 Blocking all cookies will have a negative impact upon the usability of many websites.
13.9 If you block cookies, you will not be able to use all the features on our website.
13.10 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
13.11 Deleting cookies will have a negative impact on the usability of many websites.
14.1 We are registered as a data controller with the UK Information Commissioner’s Office.
14.2 Our data protection registration number is ZA265693
15.1 This website is owned and operated by Ci5 Security Group Ltd.
15.2 We are registered in England and Wales under registration number 10856596, and our registered office is at Kemp House, 152 City Road, London, ECIV 2NX.
15.3 Our principal place of business is at Kemp House, 152 City Road, London, ECIV 2NX.
15.4 You can contact us:
(a) by post, using the postal address given above.
(b) using our website contact form.
(c) by telephone, on the contact number published on our website.
(d) by email, using the email address published on our website.
(e) by live chat when we are on line, on our website
Ci5 Security Group Ltd 25/05/2018
ICO Data Protection Registration Number: ZA265693
This document sets out the obligations of Ci5 Security™ Group Ltd (“the Company”) with regard to data protection and the rights of people with whom it works in respect of their personal data under the Data Protection Act 1998 (“the Act”).
This Policy shall set out procedures which are to be followed when dealing with personal data. The procedures set out herein must be followed by the Company, its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company.
The Company views the correct and lawful handling of personal data as key to its success and dealings with third parties. The Company shall ensure that it handles all personal data correctly and lawfully.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Act. The Act sets out eight principles with which any party handling personal data must comply. All personal data:
2.1 Must be processed fairly and lawfully (and shall not be processed unless certain conditions are met);
2.2 Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
2.3 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
2.4 Must be accurate and, where appropriate, kept up-to-date;
2.5 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
2.6 Must be processed in accordance with the rights of data subjects under the Act;
2.7 Must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
2.8 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
3. Rights of Data Subjects
Under the Act, data subjects have the following rights:
- The right to be informed that their personal data is being processed;
- The right to access any of their personal data held by the Company within 40 days of making a request;
- The right to prevent the processing of their personal data in limited circumstances; and
- The right to rectify, block, erase or destroy incorrect personal data.
4. Personal Data
Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
The Company only holds personal data which is directly relevant to its dealings with a given data subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company from time to time:
- Name & Title;
- Company/Business Name;
- Job Title;
- Telephone Number(s);
- Email Address(es);
- Social Media Labels
5. Processing Personal Data
Any and all personal data collected by the Company (including that detailed in Section 4 of this Policy) is collected in order to ensure that the Company can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by the Company in meeting any and all relevant obligations imposed by law.
Personal data may be disclosed within the Company. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
The Company shall ensure that:
- All personal data collected and processed for and on behalf of the Company by any party is collected and processed fairly and lawfully;
- Data subjects are made fully aware of the reasons for the collection of personal data and are given details of the purpose for which the data will be used;
- Personal data is only collected to the extent that is necessary to fulfil the stated purpose(s);
- All personal data is accurate at the time of collection and kept accurate and up-to-date while it is being held and / or processed;
- No personal data is held for any longer than necessary in light of the stated purpose(s);
- All personal data is held in a safe and secure manner, taking all appropriate technical and organisational measures to protect the data;
- All personal data is transferred using secure means, electronically or otherwise;
- No personal data is transferred outside of the UK or EEA (as appropriate) without first ensuring that appropriate safeguards are in place in the destination country or territory; and
- All data subjects can exercise their rights set out above in Section 3 and more fully in the Act.
6. Data Protection Procedures
The Company shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company comply with the following when processing and / or transmitting personal data:
- All emails containing personal data must be encrypted;
- Personal data may be transmitted over secure networks only – transmission over unsecured networks is not permitted in any circumstances;
- Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
- 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 should be deleted. All temporary files associated therewith should also be deleted;
- Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
- Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient. Using an intermediary is not permitted;
- All hardcopies of personal data should be stored securely in a locked box, drawer, cabinet or similar;
- All electronic copies of personal data should be stored securely using passwords and suitable data encryption, where possible on a drive or server which cannot be accessed via the internet; and
- All passwords used to protect personal data should be changed regularly and should not use words or phrases which can be easily guessed or otherwise compromised.
7. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:
- A designated officer (“the Designated Officer”) within the Company shall be appointed with the specific responsibility of overseeing data protection and ensuring compliance with the Act.
- All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company are made fully aware of both their individual responsibilities and the Company’s responsibilities under the Act and shall be furnished with a copy of this Policy.
- All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately trained to do so.
- All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately supervised.
- Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed.
- The Performance of those employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed.
- All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Act and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence under the Act.
- All contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Act.
- Where any contractor, agent, consultant, partner or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
8. Access by Data Subjects
A data subject may make a subject access request (“SAR”) at any time to see the information which the Company holds about them.
- SARs must be made in writing, accompanied by the correct fee.
- The Company currently requires a fee of £10 (the statutory maximum) with all SARs.
Upon receipt of a SAR the Company shall have a maximum period of 40 days within which to respond. The following information will be provided to the data subject:
- Whether or not the Company holds any personal data on the data subject;
- A description of any personal data held on the data subject;
- Details of what that personal data is used for;
- Details of any third-party organisations that personal data is passed to; and
- Details of any technical terminology or codes.
9. Notification to the Information Commissioner’s Office
As a data controller, the Company is required to notify the Information Commissioner’s Office that it is processing personal data. The Company is registered in the register of data controllers.
Data controllers must renew their notification with the Information Commissioner’s Office on an annual basis. Failure to notify constitutes a criminal offence.
Any changes to the register must be notified to the Information Commissioner’s Office within 28 days of taking place.
The Designated Officer shall be responsible for notifying and updating the Information Commissioner’s Office.
10. Implementation of Policy
This Policy shall be deemed effective as of 07th July 2017. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved & authorised by:
K Dargyte Operations Director
Ci5 Security™ Group Ltd