West End Security Group – Privacy Notice Version 1.2 20.8.19
Welcome to the West End Security Group’s privacy notice. The West End Security Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after any personal data we collect from you or that you provide to us and tell you about your privacy rights and how the law protects you.
1. Introduction
1.1 The West End Security Group (collectively referred to as “WESG”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal information.
1.2 This Privacy Notice (“Notice”) describes how we collect and use personal information about you during your relationship with us, in accordance with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The Notice sets out your privacy rights and how the law protects you.
1.3 This Notice applies to all categories of WESG members, including Associate Members (collectively referred to as “Members”), those individuals who contract with WESG for the provision of services, all persons who access and use our application (“app”), members of Westminster City Council (WCC) and the Metropolitan Police Service (MPS), (collectively referred to as “Partners”) and any other individual who engages with WESG for reasons associated with the aims and objectives of WESG (collectively referred to as “Stakeholders”).
1.4 It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
1.5 We reserve the right to amend this Notice at any time without notice to you so, if required, please check to ensure that you are referring to the latest copy of this Notice. We may also notify you in other ways from time to time about the processing of your personal data.
2. Data Controller
2.1 The West End Security Group, Bourne House, Queen Street, Gomshall, Surrey, GU59LY, telephone number, 07818 011917, is a “data controller” for the purposes of the GDPR. This means that we are responsible for determining the purposes and means of processing personal information about you.
2.2 We have appointed Michael Wood, Bourne House, Queen Street, Gomshall, Surrey, GU59LY, telephone number, 07818 011917, email – michaelwood@monardasolutions.com, to oversee compliance with this Notice (“the Data Privacy Manager”). If you have any questions about this Notice or how we handle your personal information, please contact the Data Privacy Manager.
2.3 You have the right to make a complaint at any time to the ICO (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.
3. Data protection principles
3.1 We will comply with data protection law. This says that the personal information we hold about you must be:
3.1.1 Used lawfully, fairly and in a transparent way
3.1.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
3.1.3 Relevant to the purposes we have told you about and limited only to those purposes
3.1.4 Accurate and kept up to date
3.1.5. Kept only as long as necessary for the purposes we have told you about
3.1.6 Kept securely.
4. The kind of information we hold about you
4.1 Personal data, or personal information, means any information about an identified or identifiable natural person. It does not include data where the identity has been removed (anonymous data). There are also “special categories” of more sensitive personal data, which require a higher level of protection.
4.2 We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
4.2.1 Identity Data includes first name, last name, title and occupation
4.2.2 Contact Data includes billing address (for members and contractors only), the company you work for, registered office address, email address and telephone numbers
4.2.3 Financial Data (for members and contractors only), includes bank account details
4.2.4 Transaction Data (for members and contractors only), includes details of membership services you have purchased form us and details about payments to and from you
4.2.5 Technical Data includes internet protocol (IP) address, your login data, 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 our app and any other information obtained through electronic means
4.3 We do not collect, use and share Aggregated Data such as statistical or demographic data for any purpose nor do we 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). We do not collect any information about criminal convictions and offences.
4.4 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.
5. How is your personal information collected?
5.1. We collect personal information about you when you correspond with us directly by email or by phone or in person. This specifically includes personal data you provide when you:
5.1.1 Become a member of WESG,
5.1.2 Subscribe to our app. Please note that our app “WESG Incident Alert,” is a gated or closed app and will not be available to the general public. Access will be via a procedure managed and controlled by WESG and controlled through the use of authorised credentials.
6. The lawful basis for WESG processing your data is as follows:
6.1 Legitimate Interest: This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
6.2 Performance of a Contract: This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
6.3 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
6.3.1 To register you as a WESG member and to administer your membership
6.3.2 To add you as a WESG app scheme member and manage the services within this facility
6.3.3 To provide you with the services or information you have requested or that otherwise form part of your membership
6.3.4 Where we need to perform the contract we have entered into with you
6.3.5 Where we need to comply with a legal or regulatory obligation
6.3.6 To maintain our own accounts and records
6.3.7 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
6.3.8 Where we have obtained your consent
6.4 We may also use your personal information in the following situations, which are likely to be rare:
6.4.1 Where we need to protect your interests (or someone else’s interests).
6.4.2 Where it is needed in the public interest or for official purposes
6.5 We will not use your personal data in connection with any marketing or related purposes.
7. Consent
7.1 Generally, we do not rely on consent as a lawful basis for processing your personal data and we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7.2 We will seek your agreement for inclusion in our app and at that time, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to participate as a scheme member.
10. If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to administer your membership or perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel the agreement you have with us but we will notify you if this is the case at the time.
11. Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
12. Automated decision-making
We do not envisage any decisions will be taken about you by automated means, however we will notify you in writing if this position changes. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
13. Data sharing
13.1. We may have to share your Data with third parties. We will only share your Personal Data with third parties where required by law and/or where it is necessary to administer your relationship with us
13.2 “Third parties” includes third-party service providers such as our contractors, suppliers and designated agents who deliver services on our behalf. We may also need to share your personal information with a regulator or to otherwise comply with the law.
13.3 Third parties in the United Kingdom and the EU are subject to the provisions of the GDPR or similar regulations in relation to your personal data.
13.4 Our third-party service providers are required to take appropriate security measures to protect your personal information and we do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
14. Sharing Data with UK Public Bodies
14.1 Separately to the above, WESG may share your data with The Metropolitan Police Service, the City of Westminster Council and other public and governmental bodies in connection with the administration and management of the West End Security Group.
14.2 Generally, the parties will only share personal data in connection with the management of the West End Security Group, in compliance with their own legal obligations, and the enforcement and administration of justice. However, each party may use your personal data for their own independent purposes where this is required or permitted by law.
14.4 Each party is responsible for its own obligations as a ‘controller’ under the GDPR but if you have any questions about how your data may be shared please contact the Data Privacy Manager.
15. Transfers outside the EU
15.1 We transfer your personal data outside the European Economic Area (EEA) as some of our data is hosted on servers in the United States of America (US), so the processing of data by these external third parties will involve a transfer of data outside the EEA
15.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are implemented • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.
15.3 Please contact the Data Privacy Manager if you want further information about when transfer your information outside the EEA and the specific mechanisms used by us to ensure the protection of your personal data.
16. Data security
16.1 The GDPR requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We ensure that reasonable security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
16.2 We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
16.3 If you have any questions about our current organisational and technical security procedures, please contact the Data Privacy Manager.
Data retention
17. How long will you use my information for?
17.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
17.2 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 requirements.
17.3 Details of retention periods for different aspects of your personal information are available on request from the Data Privacy Manager.
Rights of access, correction, erasure, and restriction
18.Informing us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
19. Your rights in connection with personal information
19.1 Under certain circumstances, by law you have the right to:
19.1.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
19.1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
19.1.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
19.1.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
19.1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
19.1.6 Request the transfer of your personal information to another party.
19.2 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Privacy Manager in writing.
20. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
21.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
23. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Privacy Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this Notice, please contact the Data Privacy Manager