Privacy Policy
Introduction
This privacy notice aims to give you information on how MSS Group Limited (we, us, our) collects and processes your personal data, including any data you may provide to us via our website, email or telephone when you contact us with enquiries or in order to purchase any of our services. This website is not intended for children, and we do not knowingly collect data relating to children.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
We keep our privacy notice under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2 What information do we collect?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data: includes job title, first name and surname.
• Contact Data: includes personal and work contact details such as address, email address and phone number.
• Employer Data: includes employer name and contact details.
• Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3 How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Employer Data by filling in forms or by corresponding with us via our website, post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• request marketing to be sent to you; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Identity and Contact Data from Housing Associations.
• Technical Data from analytics providers.
4 What is the purpose and the lawful basis for us using this information?
We are required under applicable data protection legislation to ensure that we process data lawfully, fairly and in a transparent manner.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where you have provided your express consent.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you or your employer as a new customer (a) Identity
(b) Contact
(c) Employer
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to administer our business and contracts)
To process and deliver your or your employer's order and/or to provide services to you or your employer
(a) Identity
(b) Contact
(c) Employer
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to administer our business and contracts)
To manage our relationship with you or your employer which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity
(b) Contact
(c) Employer
(d) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Marketing and Communications
(d) Technical Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you or your employer (a) Identity
(b) Contact
(c) Technical
(d) Marketing and Communications Necessary for our legitimate interests (to develop our services and grow our business)
5 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will usually get your express opt-in consent before we send any marketing communications to you.
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
6 Who do we share your personal data with?
Your personal information will only be shared with third parties as a necessity and for the purposes set out in the table above. Examples may include:
• Governmental bodies or law enforcement officials who require reporting or processing activities in certain circumstances.
• Identity and Contact Data may be shared with our operatives for the delivery of a service.
• Insurance providers and brokers who supply insurance services to us.
• Professional advisers including auditors who provide our business with accreditations.
7 International Transfers
We do not currently transfer your personal data outside the UK.
8 How long will you keep my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
9 Where is my data stored and how is it secured?
Personal data is stored on our internal servers. However such data is backed up through a 3rd party provider based in the UK called Vaughan Data.
Our emails and access to office 365 is backed up by Microsoft.
Personal data will also be stored within our online systems..
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10 What are my rights in relation to my personal data?
Under the applicable data protection legislation, you have a number of rights in respect of your personal data. These include:
Right to be informed
We inform you of what personal data we hold, why we have it and what we might use this for, within this privacy notice and any other privacy policies or notices that we may provide or make available to you from time to time.
Right of access
You have the right to request access to your personal data and confirmation of what data is being processed. MSS Group Limited will usually respond to any such requests within one month.
Right to rectification
You have the right to request that any incomplete or inaccurate personal data that we hold about you is rectified.
Right to erasure
You have the right in certain circumstances to request that personal data that we hold about you is erased.
Right to restrict processing
You can request in certain circumstances that our processing of your personal data is restricted. This generally occurs if there is a concern raised about personal data. For example, should data need to be rectified, processing could be restricted until this has been resolved.
Right to data portability
The right to data portability allows you to request that your personal data is provided to you or a third party in a structured, commonly used, machine-readable format.
Right to object
You have the right to object to us processing your personal data in certain circumstances.
Right to withdraw consent
Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Rights related to automated decision making
MSS Group Limited does not carry out any automated decision making. There is always human involvement. Should we commence any automated decision making we will first discuss this with you.
11 Where can I get further information?
We are the controller and are responsible for your personal data. If you have any questions about this privacy notice, including requests to exercise your legal rights under paragraph 10 above please contact:
Name: Rebecca Brittain (HR Director)
Email address: rebecca.brittain@themssgroup.co.uk
Telephone number: 0845 2602626
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.