2. Personal Data
3. Legal Basis
6. Retention Policy
7. Data Storage
8. Your rights as the data subject
This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.
Whitecode Group is pleased to provide the following GDPR information:
Whitecode Group consists of 4 UK companies:
• Whitecode Design Associates Ltd
• Whitecode Developments Ltd
• Walker Mower Partnership Ltd
• Vitech Services Ltd
We work principally in the Building Services Design Industry providing M&E designs, inspections and building maintenance services.
2. Personal Data
The Whitecode Group uses the information collected from you to provide quotations, make telephone contact and to email you project information in addition to marketing information which may be of interest to you and your business. Although, we do not actively promote the Whitecode Group though marketing initiatives.
In you making initial contact you consent to the Whitecode Group maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services.
Whitecode Group also acts on rare occasions on behalf of its clients, in the capacity of data processor. When working exclusively as a data processor, Whitecode will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence including emails and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. Whitecode Group may from time to time use such information to identify its visitors. Whitecode Group may also collect statistics about the behaviour of visitors to its websites.
Any information Whitecode Group holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtain about you from public sources and our own suppliers such as credit referencing agencies.
Whitecode Group will only collect the information needed so that it can provide you with its services and marketing. We do not sell or broker your data.
3. Legal basis for processing any personal data
• To meet Whitecode Group contractual obligations to clients and to also respond to marketing enquiries.
• Legitimate interests pursued by Whitecode Group and/or its clients
• To promote the Whitecode Group and/or to market the services we provide.
Through agreeing to this privacy notice you are consenting to Whitecode Group processing your personal data for the purposes outlined.
You can withdraw consent at any time by emailing HR@whitecode.co.uk or by phoning 01322 476702 or writing to us, see last section for full contact details.
Whitecode Group may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Whitecode Group requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. The Whitecode Group do not broker or pass on information gained from your engagement with the Group without your consent. However, Whitecode Group may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Whitecode Group, its clients and/or the wider community.
6. Retention Policy
Whitecode Group will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.
7. Data storage
Data is held in the United Kingdom using different (multiple) servers. Whitecode Group does not store personal data outside the EEA.
8. Your rights as a data subject
At any point whilst Whitecode Group is in possession of or processing your personal data, all data subjects, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
In the event that Whitecode Group refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Whitecode Group at your request can confirm what information it holds about you and how it is processed.
You can request the following information:
• Identity and the contact details of the person or organisation (Whitecode Group) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Whitecode Group or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what Personal data is held, identification will be required. Whitecode Group will accept the following forms of ID when information on your personal data is requested:
A copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Whitecode Group is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to HR@whitecode.co.uk or by phoning 01322 476702 or writing to us, see last section for full contact details or writing to us at the address further below.
In the event that you wish to make a compliant about how your personal data is being processed by Whitecode Group or its partners, you have the right to complain to the Whitecode Group Finance Director. If you do not get a response within 30 days, you can complain to the Information Commissioners Office (ICO) The details for each of these contacts are:
Whitecode Group: Highfield House, 2-4 West Hill, Dartford, Kent DA1 2EW, or via email to firstname.lastname@example.org or by telephone 01322 289988.
ICO: Wycliffe House, Water Lane, Wilmslow, SK9 5AF