Legal

Data Protection Policy

How we process, retain, share and secure personal data, and how you can request access to or deletion of your data.

Factor IT and all its associated companies are compliant with the data protection regulations and Data Protection Act, continually monitor and update policies and processes to ensure continued compliance with Data Protection Legislation and Regulations including the General Data Protection Regulations (GDPR) and Data Protection Act 2018.

As part of the various services and products we offer our customers, and this includes system maintenance, we may hold or have access to data that can identify individuals in order to be able to provide our customers with the services, products and support that is agreed through our contracts. In all instances, access to such data is controlled and limited to specific individuals.

Processing Information

Scope and purpose of processing

Personal data is held for the purposes of the provision of IT and telecom services and related products. The personal data held is obtained in support of contractual arrangements and is necessary under the 'legitimate interests' pursued by the controller (Factor IT Services Ltd) as defined in article 6.1 of the GDPR. The facility to opt out of marketing communications remains, but excludes operational or pricing communications.

Nature of processing

FactorIT does not undertake any automated decision making as defined by article 22 of the GDPR. Data will be processed internally by the marketing department for the purposes of objective and permission-based marketing.

Duration of processing and retention

FactorIT will maintain personal data for the duration of contracts during the provision of IT and telecommunication services and products. Thereafter, the data will be held for a 'reasonable' period, depending on the nature of the relationship with the customer.

The data will be deleted when the retention of that data can no longer be justified under the provisions of the Data Protection Act and is not overruled by competing legislation or regulations. The terms against which data are held vary and are dependent on the business cycle, regulations and legislation.

Requests for information

Persons whose data are held by Factor IT and its associated companies may request their own data. These are called subject access requests. These should be submitted in writing to our postal address or via email to service@factorit.co.uk.

We will need to verify the identity of the requestor and in the unlikely event there is substantial cost to Factor IT in terms of retrieving the data, we may charge a maximum of £10. The regulations require us to respond within 28 days of the request.

Deletion of information

Persons whose data are held by Factor IT and its associated companies may request that their data be permanently deleted as stated in Data Protection Regulations and Data Protection Legislation, and such requests will be complied with as soon as practicable where a customer no longer has a relationship with Factor IT or its associated companies.

Where a requestor continues to have a business relationship with Factor IT or its associated companies, we may need to ensure that the requestor's details are replaced with those of an alternative contact to enable the continued effective management of our relationship with our customers and partners. Any such requests should be submitted in writing to our postal address or via email to service@factorit.co.uk. We will need to verify the identity of the requestor in all circumstances.

Types of Personal Data

The personal data held will include: Name, Position, Telephone Number(s), email address. No 'sensitive data' (as defined by the Data Protection Act) or 'special categories of personal data' (as defined by the GDPR) are held against any current, former or prospective (wholesale only) customers.

Categories of Data Subject

The data subjects whose data may be held by Factor IT is restricted to that of existing, former or prospective customers and associated contacts. These data fall under the category of 'personal data' and do not include any 'sensitive data' (as defined by the Data Protection Act) or 'special categories of personal data' (as defined by the GDPR).

Data sharing

There is no routine data sharing of person identifiable data. Where exceptions exist, these concern the management of systems where providers require sample data for the purposes of de-bugging systems or processes.

In these circumstances we would implement a formal data sharing agreement to ensure the transaction is handled for the purposes of the 'system fix' and to obtain a legal platform to ensure that access, security and disposal of the data adheres to our requirements in terms of current and future ISO accreditation and Data Protection legislation.

In terms of transactional data (non person identifiable data), for example direct debit data, there is a robust data sharing agreement and corresponding process for exchanging data with all suppliers. No person identifiable data is exchanged or transferred routinely.

Out of hours access

There are a number of specific roles within our organisation that require that 'specified individuals' have access to data outside of operational hours. For example, to manage and react to incidents and to access systems remotely or on site for the purposes of maintenance or in managing system failures or errors.

In these circumstances access is either on our premises or is governed by the same security measures outlined in data hosting.

Voice recording

On-site call recording is under the control of each customer; call recording data is not accessible to Factor IT. Customers should ensure that they are compliant with all relevant regulations and legislation applicable to the customer in terms of consent, security, access, resilience, backups, archiving and deletion.

ISO and risk management

Factor IT retains 9001 accreditation standards and is currently running an implementation programme with BSI to attain 27001 accreditation.
There have been no significant security incidents in the last 12 months.
The organisational risk register contains all risks identified to date and these are managed as determined by our internal processes, reporting to the organisational risk management group.