Privacy Notice - ShareFile Uploads
Document Ref PIMS12.08
All data subjects whose data is processed by TEPE Holdings Group. TEPE Holdings Group includes Clarkeprint Ltd, Clarkeprint FM Ltd and Waveney Publishing Ltd.
The Data Protection Officer and GDPR Owner are responsible for ensuring that this notice is placed in front of potential data subjects prior to TEPE Holdings Group collecting/processing their personal data.
All Employees/Staff of TEPE Holdings Group 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.
The personal data we collect from you, or that you upload to the ShareFile site will be used for the following purposes:
- To identify the documents that have been uploaded.
- To send notifications about, uploads, downloads or deletion of your files or to your folders, if you have chosen to receive them.
- To deliver any services subsequently requested by you.
- We will only use your data provided in this context, or data uploaded to ShareFile for the intended purpose(s) as outlined in the data sharing agreement that we have with your, which may form part of a broader contract with your organisation.
By providing your personal data, or the personal data of others, you are giving us consent to perform these actions.
What is Personal Data?
Under the EU’s General Data Protection Regulation 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”.
Special Categories of Personal Data
Certain data are classified under the Regulation as "special categories":
- Ethnic origin
- Political Opinions
- Religious Beliefs
- Trade-union membership
- Genetic Data
- Biometric Data
- Health Data
- Data concerning a natural person's sex life
- Sexual orientation
Consent is required for TEPE Holdings Group 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.
Why does TEPE Holdings Group need to collect and store personal data?
In order for us to provide you with the information and services that you have requested we need to collect personal data for correspondence purposes and/or service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
How TEPE Holdings Group uses your information
TEPE Holdings Group will process - that means collect, store and use - the information you provide in a manner that is compatible 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. In some instances, the law sets the length of time information has to be kept, but in most cases TEPE Holdings Group will use its discretion to ensure that we do not keep records outside of our normal business requirements.
We may pass your personal data on to our service providers who are contracted to TEPE Holdings Group during dealing with you. Our contractors are obliged to keep your details securely, and use them only to fulfil the service they provide you on our behalf. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with TEPE Holdings Group’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 so.
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Your Rights as a Data Subject
Data subjects have the following rights regarding data processing, and the data that is recorded about them:
- To make subject access requests regarding the nature of information held and to whom it has been disclosed
- To prevent processing likely to cause damage or distress
- To prevent processing for purposes of direct marketing
- To be informed about the mechanics of automated decision-taking process that will significantly affect them
- Not to have significant decisions that will affect them taken solely by automated process
- To sue for compensation if they suffer damage by any contravention of the GDPR
- To take action to rectify, block, erase, including the right to be forgotten, or destroy inaccurate data
- To request the ICO to assess whether any provision of the GDPR has been contravened
- The right for personal data to be provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller
- The right to object to any automated profiling without consent
You may make a subject access request, or withdraw consent for processing at any time by writing to the Data Protection Officer at firstname.lastname@example.org or TEPE Holdings Ltd, 45-47 Stour Street, Birmingham, B18 7AJ.
If you have concerns about how TEPE Holdings Group is processing your personal data and haven't received a satisfactory response from the Data Protection Officer you can make a complaint directly to the Information Commissioners Office, you can find further details about how to go about this at https://ico.org.uk
This document is valid as of 01/03/2018.
This document is reviewed periodically and at least annually to ensure compliance with the following prescribed criteria.
- General Data Protection Regulation
- Legislative requirements defined by law, where appropriate