1. Introduction
Microlink PC (UK) Ltd is committed in protecting data subject’s privacy and respecting data subject’s personal data and special category data at all times.
Microlink provides a Workplace Adjustment Service which supports colleagues who have a disability or long-term health condition that may require changes to their working environment or role to minimise the impact of their disability or condition. These changes (adjustments) can be physical. The aim of this policy and procedure is to ensure that Microlink safeguards the privacy of our customers. The referral forms used to collect the personal data will incorporate privacy controls which will affect how we will process your data.
All users have a role to play and a contribution to make to the safe and secure use of technology and the information (both stored electronically and in any other form) that it holds.
This policy needs to be applied as soon as personal data is collected from the data subject.
2. Methods of using your personal data
- General categories of personal data including special category data we may process.
- the source and specific categories of personal data including special category data that we have not directly collected from the data subject.
- the purpose for which we may process personal data including special category data.
- legal basis for processing
2.1 Enquiry Data
We may process personal information contained in any enquiry through a referral form the data subject submits to us regarding products and/or services (“enquiry data”). The legal basis for processing is by you providing consent or legal obligation under the equality act.
2.2 Transaction data
We may process information relating to transactions, including purchases of goods and services, that the data subject enters into with us through our clients. The transaction data may include the contact details, card details and the transaction details of the data subject. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
2.3 Other way of processing
In addition to the specific purposes for which we may process data subject’s personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1
Depending on the recommendations made by the staff at Microlink, it may be required to share your data with third party suppliers for the purposes of carrying out assessment, training or installation.
3.2
We may disclose the personal data collected from the data subject to our suppliers or subcontractors insofar as reasonably necessary for the purposes of carrying out assessment, training or installation.
3.3
We may disclose your enquiry data to one or more selected third-party suppliers of goods and services, enabling them to provide the services Microlink are contracted to on behalf of your employer. Some third parties will act as a data controller in relation to the enquiry data that we supply; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.4
In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Retaining and deleting personal data
4.1
This Section 4 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 data.
4.2
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3
We will retain and delete your personal data as follows:
- when processing personal data collected at the transaction is complete, the data will be retained for a period of 7 years according to the equality act 2010. At the end of which period, the data will be archived and destruction after 15 years.
4.4
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention of special category data will be determined based on the contractual agreements Microlink has with supplier.
4.5
Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Amendments
5.1
We may update this policy from time to time by publishing a new version on our website.
5.2
You should check this page occasionally to ensure you are happy with any changes to this policy.
6. Your rights
In this Section 6, we have summarized the rights that you have under UK GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under GDPR are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to withdraw consent.
- the right to object to automated processing.
- the right to complain to a supervisory authority
6.1 Data subject’s request to access the data
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data after you have completed our Data Subject Access Request Form.
6.2 Data Subject’s request for rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed by completing our data rectification request form.
When a data subject requests rectification or information under UK GDPR, the request to be actioned first by the relevant member of staff. If there is a problem with rectifying the data, then the request must be logged and passed onto the Data Protection Officer. Once the action has been completed the date and the nature of the corrective action are logged.
6.3 Data subject’s right for erasure
In some circumstances you have the right to the erasure of your personal data without undue delay by completing our Data Erasure Request form. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
When a data subject requests that the data to be erased under the UK GDPR, the request is logged (form) and passed onto the Data Protection Officer.
The DPO will then assess the request and see if it can be legally acted upon. If there is another legal ground for processing other than consent and continued processing poses no risk to the rights and freedoms of the data subject, then the data subject will be informed where and how processing will continue. E.g. an ongoing criminal case, legal obligation to process etc.
Once the right to erasure has been confirmed then all applicable data relating about the data subject, is to be removed from processing.
All data necessary to maintain the erasure recorded is to be moved to a nonprecessing part of the data storage area.
Once the action has been completed the date and the nature of the corrective action are logged and the data subject is informed that their details have been removed.
6.4 Data subject’s right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
When a data subject request to restrict processing under the UK GDPR, the requested is logged and passed onto the Data Protection Officer.
The DPO will then assess the request and see if it can be legally acted upon. If there is another legal ground for processing other than consent and continued processing poses no risk to the rights and freedoms of the data subject, then the data subject will be informed where and how processing will continue. E.g. an ongoing criminal case, legal obligation to process etc.
Once the right to restrict has been confirmed then all applicable data relating about the data subject, is to be restricted from processing.
The records for this data subject are to be marked “not for processing” and moved to a not for processing area of the data storage area.
The size of the record is sufficient just to contain enough information about the data subject to ensure that the restriction is respected in future.
Once the action has been completed the date and the nature of the corrective action are logged and the data subject informed of the outcome and its effects.
6.5 Data subject’s right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
When a data subject objects to the processing of their data under the UK GDPR, the requested is logged and passed onto the Data Protections Officer.
Once the action has been completed the date and the nature of the corrective action are logged.
6.6 Data Portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.7 Withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.8 To lodge a complaint
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the UK of your habitual residence, your place of work or the place of the alleged infringement.
You may exercise any of your rights in relation to your personal data. We require proof of your identity before we can disclose personal data. Proof of your identity should include a copy of two documents such as your birth certificate, passport, driving licence, official letter addressed to you at your address e.g. bank statement, recent utilities bill or council tax bill. The documents should include your name, date of birth and current address. If you have changed your name, please supply relevant documents evidencing the change. Your request will be processed within 30 calendar days upon receipt of a fully completed form and proof of identity.
