the 99&One

Data Protection Policy

Introduction

99&One is the trading name of TeleWare Plc, part of the TeleWare Group of companies. TeleWare Plc is committed to being transparent about how it collects and uses data about people with whom it deals with to operate. These may include, but are not exclusive to current, past and prospective employees, suppliers, clients, customers, partners and others with whom it communicates.  This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.

Personal data must be dealt with responsibly however it is collected, recorded and used and regardless of the medium used.

We regard the lawful and correct treatment of personal data by TeleWare Plc as very important to successful operations, and to maintaining confidence between those with whom we deal and ourselves.  We ensure that our organization treats personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of data protection, as enumerated in the General Data Protection Regulation (GDPR).

The Information Commissioners Office

The Information Commissioners Office (ICO) is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. TeleWare Plc Registration Reference is: ZA137856.

The Data Controller

The Data Controller and the person with responsibility for data protection compliance within TeleWare Plc and its subsidiaries is Claire Iverson, Company Accountant. Copies of registrations and policies or requests for further information are available from The Data Controller.

 Definitions

“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.

The Data Protection Principles

The organisation processes personal data in accordance with the following data protection principles:

  • The organisation processes personal data lawfully, fairly and in a transparent manner.>
  • The organisation collects personal data only for specified, explicit and legitimate purposes.
  • The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
  • The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
  • The organisation keeps personal data only for the period necessary for processing.
  • The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

TeleWare Plc will inform employees, clients and partners the reasons for processing their personal data, how it uses such data and the legal basis for processing. It will not process personal data of individuals for other reasons.

Where TeleWare Plc relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Where TeleWare Plc processes special categories of personal data or criminal records data in relation to applications for employment or during employment it does so in accordance with GDPR and current Employment legislation.

The organisation will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.

TeleWare Plc keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Data Subject

Under GDPR as a ‘data subject’, individuals have a number of rights in relation to their personal data.

Subject Access Request

Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell him/her:

  • If his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual.
  • To whom his/her data is or may be disclosed.
  • For how long his/her personal data is stored.
  • His/her rights to rectification or erasure of data, or to restrict or object to processing.
  • His/her right to complain to the Information Commissioner if he/she thinks the organisation has failed to comply with his/her data protection rights; and if the organisation carries out automated decision-making and the logic involved in any such decision-making.

The organisation will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

To make a subject access request, the individual should send the request to claire.iverson@teleware.com. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.

TeleWare Plc will normally respond to a request within a period of one month from the date it is received.

If a subject access request is manifestly unfounded or excessive, TeleWare Plc is not obliged to comply with it. Alternatively, TeleWare Plc can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request which TeleWare Plc has already responded. If an individual submits a request that is unfounded or excessive, TeleWare Plc will notify him/her that this is the case and whether or not it will respond to it.

Other Rights

Individuals have a number of other rights in relation to their personal data. They can require the organisation to:

  • Rectify inaccurate data.
  • Stop processing or erase data that is no longer necessary for the purposes of processing.
  • Stop processing or erase data if the individual’s interests override TeleWare Plc’s legitimate grounds for processing data.
  • Stop processing or erase data if processing is unlawful.
  • Stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override TeleWare Plc’s legitimate grounds for processing data.
  • To ask the organisation to take any of these steps, the individual should send the request to: claire.iverson@teleware.com.

Data Security

TeleWare Plc takes the security of personal data seriously, to this end we have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure and to ensure that data is not accessed, except by employees in the accordance of their duties. We operate an Information Security Management System (ISMS) in accordance with ISO 27001:2015 as a framework to protect the confidentiality, integrity and availability of data we hold.

Where TeleWare Plc engages third parties to process data on its behalf, such parties do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

International Data Transfers

TeleWare Plc will not transfer personal data to countries outside the EEA.

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