Data Protection & Privacy Policy

May 2020

All references to ‘our’, ‘us’, ‘we’, or ‘Latch’ within this policy are deemed to refer to February London Ltd t/a Latch, its subsidiaries, affiliates and associates.

Scope

All data subjects whose personal data is collected, in line with the requirements of GDPR.

Responsibilities

The Data Privacy Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to Latch collecting/processing their personal data.

All Employees/Staff of Latch who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

Privacy notice

Who are we?

Latch is a design agency, located in Newbury, Berkshire.

Our Data Privacy Officer and data protection representative is Toby Dyson who can be contacted directly here:

The personal data we may collect and process from you is:

  • The identity data we collect includes first name, last name, username or similar identifier
  • The contact data we collect includes landline phone number, mobile phone number, extension number, email address, company address, billing address, delivery and postal address
  • The financial data and transaction data we collect to conduct business includes bank account details, details about your payments and services you have purchased from Latch
  • Your preferences in the marketing you receive from Latch
  • Data you supply to us for marketing purposes

The personal data we collect will be used for the following purposes:

  • To carry out day to day business with our clients to supply and provide a professional service
  • To verify identification of a data subject

Our legal basis for processing the personal data:

  • The legal judicial process requires this information before it can act on your behalf.

Any legitimate interests pursued by us, or third parties we use, are as follows:

  • Third parties that may receive data are: marketing software resources, service providers and HMRC.

We will not hold special personal data such as:

  • Racial
  • Ethnic origin
  • Political opinions
  • Religious beliefs
  • Philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data
  • Health data
  • Data concerning a natural person’s sex life
  • Sexual orientation

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Latch to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting our Data Privacy Officer at the following email address [email protected] and requesting a consent withdrawal form GDPR DOC 4.6a. This can be issued upon request.

Disclosure

Latch will not pass on your personal data to third parties without first obtaining your consent. Any third parties we use are vetted suppliers with a good reputation and may only receive your personal data for the following purpose(s) as part of the processing activities:

  • Website Hosting
  • To assist in meeting your marketing needs
  • Any work you request from us

Retention period

Latch will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal and accounting requirements. By law Latch are required to keep basic information about our customers for six years after they cease being customers for tax purposes. Personal data use is regularly reviewed and deleted once consent has been removed or it has been used for the express purpose we collected it for.

Your rights 

At any point while we are in possession of or processing your personal data, you, the data subject, 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.
  • Right to judicial review: in the event that Latch refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

If you wish to exercise any of your rights as a data subject, please contact our Data Privacy Officer.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Latch (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Latch’s DPO. The ICO’s website can be viewed at www.ico.org.uk.

The details for each of these contacts are:

 

ICO contact details

Information Commissioner’s Office
casework.ico.org.uk
0303 123 1113

Latch’s DPO contact details

Toby Dyson
[email protected]
0203 176 2629

Privacy Statement

This notice advises how Latch collect and maintain your data during processing.

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How do you use my information?

This privacy notice tells you how we, Latch, will collect and use your personal data for the purpose of providing specific marketing purposes.

Why does you need to collect and store personal data?

In order for us to provide you with our services we need to collect personal data for correspondence purposes and detailed legal service provision.

In terms of being contacted for marketing purposes Latch will contact you for explicit consent.

Does Latch share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Latch in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Latch’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Latch use the personal data it collects about me?

Latch will process (collect, store and use) the information you provide inline with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Latch is required to retain information in accordance with the law, such as information needed for tax or audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Latch contact me?

We will only contact you during the course of our working together or for marketing purposes, and then only if you have given express consent.

Can I find out the personal data that the organisation holds about me?

Latch at your request, can confirm what information we hold about you and how it is processed. If Latch does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • 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 Latch or a third party, 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.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • 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.
  • 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.

What forms of ID will I need to provide to access this?

Latch accepts the following forms of ID when information on your personal data is requested: Passport or driving licence to prove you are the data owner.