General Date Protection Regulation (GDPR)

General Data Protection Regulation (GDPR)

gdprAt Lateo Surveillance Ltd we take our responsibilities under the General Data Protection Regulation (GDPR) and its legislation The Data Protection Act 2018 seriously.  The managing director of Lateo Surveillance is proud to be a fully compliant data controller registered with the information commissioner’s office and standard setter within the investigation industry. We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our employees, contractors, professional advisors, customers and clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information Commissioners Office Guidance Regarding Private Investigators

The general position of the Information Commissioner’s Office states:  It is unlikely a private investigator would be a data processor. This is due to the nature of their work, particularly those carrying out any form of surveillance investigation. This is due to the high degree of independence, expertise, control and processing of personal information such as writing and retaining reports, obtaining photographic or video evidence.

For the avoidance of doubt the General Data Protection Regulation (EU) 2016/679  (GDPR) states the following:

The fact that one organisation provides a service to another organisation does not necessarily mean that it is acting as a data processor. It could be a data controller in its own right, depending on the degree of control it exercises over the processing operation.

In the vast majority of cases, a Private Investigator should assume the joint responsibilities of a Data Controller and provide you with a signed contract detailing their responsibilities.

Privacy Notice 

Company Information:

Lateo Surveillance is a limited company and registered in England under company number 08023705. 

Registered address: 7 Front Street, Shotley Bridge, Consett, County Durham, DH8 0HH. 

Main trading address: Portland House, Belmont Business Park, Durham, DH1 1TW.

VAT number: 138691384.

Data Protection Officer: Mr Thompson.

Email address: dpo@lateosurveillance.co.uk.

Telephone number: +44 (0) 7974659 016.

Postal Address: Portland House, Belmont Business Park, Durham, DH1 1TW.

Regulated by: The Information Commissioners Office registration number ZA047569.

The principal investigator of Lateo Surveillance Ltd is a member of The Association of British Investigators – registration number F1755 (Full Member)

1. What does this notice cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

2. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

3. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

4. What personal data do we collect?

We only collect enough information to enable us to carry out our professional services.  The personal data allows us to manage your portal, carry out regulatory checks to meet our legal obligations, prevent and detect crime and to keep you up to date with our services.  You will be asked to supply this information during the registration process.   

Please note: you are not under any obligation whatsoever to supply any information, however, unfortunately, we will not be able to assist in delivering our professional without the information requested.

5. How will you use my personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

Providing and managing your account and portal.

Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.

Communicating with you. This may include responding to emails or calls from you, receiving or sending instructions and delivering our services.

Supplying you with information by email or post that you have agreed to.

Checking the validity of an instruction or registration in order to meet our legal obligations.

Carry out regulatory checks to meet our legal obligations.

6. How long will you keep my personal data?

We will not keep your personal data longer than is necessary in light of the reason(s) for which it was first collected.

Your personal data will, therefore, be kept for the following periods:

Employees, contractors, partners and professional advisor’s; no fixed period.

Client and customers; upon completion of the service or contract.

Note; Basic client and customer information may be retained relating to financial transactions such as invoices – no personal information relating to the subject(s) of an investigation or security service will be retained.

7. How and where do you store or transfer your personal data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.  If in the course of a service, investigation or security service your information is required to be transferred outside of the UK this will only be done within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

7.1 Our online portal is password protected and encrypted.  You are responsible to ensure the safety of your own password. Tips when creating a strong password: use at least one special character, one number, one case-sensitive letter within the password using linked phrase.  For more information please contact us.

7.2 Sensitive documentation will always be password protected.

7.3 Storage devices used will always be protected using passwords and encryption.

8. Do you share my personal data?

There may be occasions when your information may be shared with our employees, contractors, partners and professional advisors but only on a ‘need to know’ basis in the course of an investigation or delivering a security service.  These employees, contractors, partners and professional advisors are governed by the rules of the GDPR. We will not share any of your personal data with any third parties for any purposes other than for which it was originally intended.

Please note this is subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

9. How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

To ensure you receive the subject access request as quickly as possible this should be made in writing and sent to the email or postal addresses shown in Part 10. To make this as easy as possible for you, please contact us and request a subject access request form. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How do I contact you?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details;

For the attention of: The Data Protection Officer

Email address: dpo@lateosurveillance.co.uk

Telephone number: +44 (0) 797 4659 016

Postal Address: Portland House, Belmont Business Park, Durham, DH1 1TW

11. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

 

DATA PROCESSING STATEMENT

1. Nature of work – Investigation and Security Services in the private sector.

2. Dated: 25 May 2018.

2.1 Designated Data Controller: Mr Thompson

3. Description of processing:

3.1. The following is a broad description of the way this organisation processes personal information. To understand how your own personal information is processed you may need to refer to any personal communications you have received with the data controller, check our privacy notices provided or contact us to ask about your personal circumstances.

3.2. Reasons/purposes for processing information:

We process personal information to enable us to:

  • provide investigatory and security services on the written instructions of a data controller (our client) and members of the general public upon completion of a contract to maintain our own accounts and records and to support and manage our employees, agents, professional advisors, partners, contractors, clients and customers.

4. Type/classes of information processed:

4.1. We process information relating to the above reasons/purposes. This information may include:

  • personal details
  • the investigation and security brief, results and related information
  • lifestyle and social circumstances
  • family details
  • goods and services
  • financial details
  • education and employment and/or business details

4.2. We also process sensitive classes of information that may include:

  • physical or mental health details
  • racial or ethnic origin
  • trade union membership
  • religious or other beliefs
  • criminality

5. Who the information is processed about:

5.1. We process personal information about:

  • customers and clients, including prospective clients
  • witnesses
  • the subjects of investigations
  • business contacts
  • agents, advisers and other professional experts
  • suppliers
  • employees

6. Who the information may be shared with:

6.1. There may be occasions when your information may be shared with our employees, contractors, partners and professional advisors but only on a ‘need to know’ basis in the course of an investigation or delivering a security service.  These employees, contractors, partners and professional advisors are governed by the rules of the GDPR. We will not share any of your personal data with any third parties for any purposes other than for which it was originally intended.  What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.

6.2. Where necessary or required we share information with:

  • financial organisations
  • credit reference, debt collection and tracing agencies
  • police forces
  • professional investigators
  • security consultants
  • government
  • business associates and other professional bodies and advisers
  • suppliers
  • current, past or prospective employers
  • education and examining bodies
  • family, associates or representatives of the person whose personal data we are processing

7. Trading and sharing personal information:

7.1. Personal information is traded and shared as a primary business function. For this reason the information processed may include name, contact details, family details, financial details, employment details, and goods and services. This information may be about customers and clients.

7.2. The information may be traded or shared with business associates and professional advisers, agents, service providers, customers and clients.

7.3 Information obtained will never be sold and only used for the purpose for which it was intended.

8. Undertaking research:

8.1. Personal information is also processed in order to undertake research.

8.2. For this reason the information processed may include name, contact details, family details, lifestyle and social circumstances, financial details, good and services.

8.3. The sensitive types of information may include physical or mental health details, racial or ethnic origin and religious or other beliefs.

9. Consulting and advisory services:

9.1. Information is processed for consultancy and advisory services that are offered.

9.2. For this reason, the information processed may include name, contact details, family details, financial details, and the goods and services provided.

9.3. This information may be about customers and clients.

9.4. Where necessary this information is shared with the data subject themselves, business associates and other professional advisers, current, past or prospective employers and service providers.

10. Transfers:

10.1. It may sometimes be necessary to transfer personal information overseas.

10.2. When this is needed information may be transferred to countries or territories around the world.

10.3. Any transfers made will be in full compliance with all aspects of the Data Protection Act.

10.4 For more information regarding transfers contact the Data Protection Officer: dpo@lateosurveillance.co.uk

11. More information 

Should you require more information relating to our compliance you can request the following information by contacting our DPO:

11.1.  GDPR Data Protection Policy

11.2.  GDPR Data Retention Policy

11.4.  GDPR Data Processing Agreement

11.5.  GDPR Data Sharing Contract

 

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Copyright 2016 Lateo Surveillance Ltd
Lateo Surveillance Ltd is a company registered in England. Company Reg. No. 08023705. VAT Reg No 138 6913 84.