Privacy Policy & Notice

Privacy Policy

1. Introduction 

Ipswich Computer Services Ltd holds information which has to be managed in accordance with the General Data Protection Regulation (GDPR). This policy describes the actions we take to ensure compliance with the policy. 

We recognise that it is not our data to use as we wish, but it is your data that we are merely custodians of.  We fully respect that you have entrusted your data with us and we will take care to ensure that your data is fully protected. 

This policy ensures we: 

    • comply with data protection law and follow sound practice 
    • ensure the rights of staff, customers, and business partners are adhered to 
    • are open about the way we process and manage information 
    • reduce the risk of a data breach 
    • are able to respond quickly in the event of a breach 

2. Scope 

This policy applies to all Ipswich Computer Services Ltd activities irrespective of location, all staff and direct contractors. 

3. Why we hold data? 

We hold personal data to enable us to: 

    • manage our employees 
    • provide I.T. services to our customers 
    • market our services 

4. What basis do we hold and process data? 

We will only use personal information for lawful business purposes set out under the GDPR. 

Wherever possible we will not rely on consent to hold data; we will identify another ground to justify holding data.  

We will only hold and process data on the basis that we have explained; We will not seek to process data in a way which is different from the original intent. 

5. Sensitive Personal Data 

We will not hold or process sensitive personal information unless the security and management arrangements of the GDPR higher standards have been met. 

We will undertake a Data Protection Impact Assessment (DPIA) and Risk Assessment to determine the appropriate measures to be taken to protect any Sensitive Personal Data that we hold or process. 

6. Children 

At Ipswich Computer Services Ltd we do not hold or process data about children. 

If in the future we do process data on children, we will hold and process it at the higher standard. 

7. Notices 

We will be open, accurate, and clear in explaining how personal data will be used. 

8. Individuals Rights 

We will provide requested data as promptly as we can, and in accordance with timescales set out under the GDPR. 

Processes for contacting us to request data that we hold will be clearly available and easy to understand. 

We aim to acknowledge all requests for data within 24 hours. 

9. Data Management 

9.1 Minimisation of Data 

We will hold the minimum amount of data that is necessary for the function of our business. 

9.2. Accuracy 

We will keep information up to date and correct any inaccurate data that is identified. 

9.3 Retention of Data 

We will not hold data longer than is necessary for our business purposes.  

9.4 Transferring Data Overseas 

We will not export your data overseas without ensuring appropriate data protection arrangements are in place. 

9.5 Automated Decision Making 

We will not use automated decision making solely when making a decision which will have a direct impact on an individual. 

10. Protective Measures 

10.1 Security of Data 

We will ensure that we apply appropriate industry standard security measures when securing and handling personal data. 

We will take specialist advice, where necessary, to ensure our security measures are providing the expected level of protection. 

10.2 Incident Reporting 

We will treat all security incidents as a serious matter and provide appropriate resources to their investigation. 

We will report security incidents as required by the GDPR and the Information Commissioner’s Office (ICO). 

Staff and direct contractors are required to report any incidents or breaches of this policy as soon as possible. 

Any findings as a result of a security incident will be used to improve our systems, processes, and training. 

10.3 New Systems and Processes 

We will ensure privacy is considered at the outset of any new information processing systems and business processes. 

10.4 Third Parties We Work With 

Depending on the type of supplier, we undertake one of the following: 

    • review their terms and conditions to ensure they protect data in accordance with GDPR requirements 
    • provide details of the information we hold and process, ensure they understand their responsibilities in helping us secure it, and formally agree the arrangements 

11. Direct Marketing 

When obtaining marketing data, we will ensure it is from a GDPR compliant supplier. 

11.1 Business to Business (B2B) 

We will ensure that B2B marketing communications have a clear method of opting out of further communications from us. 

We will take care when adding details to our mailing lists to ensure we treat sole traders and partnerships as Business to Client (B2C) parties. 

11.2 Business to Client (B2C) 

We will ensure we gain consent prior to adding you to our mailing list. 

We will ensure that B2C marketing communications have a clear method of opting out of further communications from us. 

12. Complaints 

We will investigate complaints or disputes conceding the holding or processing of personal data promptly 

If necessary, we will cooperate with the ICO in the investigation and resolution of complaints and will aim to comply with any recommendations. 

13. Compliance 

13.1 Failures 

Failure to comply with this policy by staff will be dealt with under our disciplinary procedures. 

Failure to comply with this policy by direct contractors will be dealt with under the terms of the contract between us, which could include termination. 

13.2 Training 

We will train our staff on the GDPR and provide refresher training as required. 

14. Accountability 

We will have documentary evidence to support our GDPR compliance, including: 

    • analysis of data types and their flows 
    • the locations (logical and physical) where data is held 
    • the people with access to the information 
    • assessment of the suitability of the security controls applied 
    • details of arrangements we have with our suppliers to maintain protection 

Privacy Notice

1. Introduction 

Ipswich Computer Services Ltd is an Information Technology outsourcing company. Under GDPR we are a Data Controller. This means we decide how your personal data is processed and for what purposes. 

At Ipswich Computer Services Ltd we know that information relating to information technology can at times be highly sensitive.  We look after our clients’ data the same way we look after our own. We don’t sell personal data or make it available to any other organisation. Our Privacy Policy sets out the way in which we protect and manage your data. 

We know that the data is not ours – we are merely custodians of your valuable information. 

2. What do we hold data for? 

We do not hold any data on Children. 

2.1 As a Data Controller: 

For managing business relationships in the provision of services 

To manage our employees 

For marketing and information purposes 

3. How do we Process Data? 

We comply with our obligations under the GDPR by: 

  • Ensuring personal data is accurate and correcting inaccuracies discovered or notified to us 
  • Not collecting excessive amounts of information 
  • Only retaining information for as long as is necessary 
  • Providing appropriate protection of data confidentiality against unauthorised access and disclosure through appropriate technical, physical, and procedural measures 

4. What is the Legal Basis for Processing Data? 

Marketing and information is to business customers only.  We send information by email on the basis of Legitimate Interest. We do not need consent for this, but we ensure people have an easy way to opt out of any communications.  

Our employee data is managed on the basis of Legitimate Interest and Contract of Employment. Processing data is required for carrying out responsibilities under Employment Law. 

We process data on behalf of our clients on the basis of Legitimate Interest. 

5. Transfer Overseas 

We do not knowingly transfer personal data overseas. Our major IT providers all have operations within the European Union and claim to be fully GDPR compliant. 

6. Data Retention 

We have a Data Retention Policy which is based around statutory and legal requirements. 

7. Sharing your Personal Data 

Your personal data is treated confidentially and is not sold. We do not share marketing data. 

It may occasionally be necessary for us to share certain information with other providers and the data shared will be the minimum necessary. We will seek assurance that the third-party provider is GDPR compliant. 

8. Website 

Our website has two features that impact privacy: 

  • Contact Us form
  • Cookies 

Completing our Contact Us form involves data being processed via our website which is transmitted to us via email. Personal data is not retained on our web site. Communications between your browser and the website are encrypted. 

Session cookies are required for the operation of our website.  These will be deleted from your computer when you close your browser. 

9. Your Rights and Your Personal Data 

To make a Subject Access Request, please write to us detailing the information that you seek. Please try to be as specific as possible, because as a small company searches can be expensive. We will charge a reasonable fee based on the administrative cost for searches that we deem to be excessive or unfounded. We will charge a fee for repeat searches, even if the original search was free. Requestors should not assume we have received the request until they have received an acknowledgement. 

To make a request for deletion or rectification, please write to us, speak to us or email detailing the information that you believe needs correcting, and evidence of why the data we hold is incorrect. We will confirm receipt of the request in writing.