This privacy notice tells you what to expect when we collect personal information. This applies to information we collect about:
• Clients and prospective clients
• Contacts at firms we deal with
• Visitors to our website
• People who contact us
• Job applicants and our current and former employees
We may use personal data to provide services requested from us, manage accounts, make decisions, detect and prevent financial crime, for analysis and assessment, and to ensure that we comply with applicable legal and regulatory requirements. We do not pass your personal data to external marketers and would not do so without your explicit permission.
What is Personal Data?
Under the General Data Protection Regulation, personal data is defined as:
“Any information relating to an identified or identifiable natural person”
A further level of personal data is Sensitive, or ‘special category’ personal data. The following data falls within this definition:
racial or ethnic origin
religious or philosophical beliefs
trade union membership
data concerning health
data concerning a natural person’s sex life or sexual orientation.
Other than for our employees, we record and retain very little data that would constitute ‘sensitive personal data’ as it largely has very little relevance to what we do as a business.
Your Data Rights
Under the General Data Protection Regulation every individual has the following rights:
· the right to be informed; – i.e. what data is being gathered and how it is being used and stored
· the right of access; i.e. the right to see what personal data any company has relating to you
· the right to rectification; e.g. ensuring data are accurate and up to date, and corrected if not
· the right to erasure; – often referred to as ‘the right to be forgotten’ – erasure of all data at your request in certain circumstances
· the right to restrict processing; i.e. to limit data usage
· the right to data portability; i.e. for your data to be sent to another company on your behalf, at your request
· the right to object; and
· the right not to be subject to automated decision-making including
profiling. MTS do not use any automated decision-making processes.
In order to legally process personal data we need to rely on one or more of the following conditions:
(a) Consent: you have given clear consent for us to process your personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract we have with the individual,
(c) Legal obligation: the processing is necessary for us to comply with the law
(f) Legitimate interests: the processing is necessary for our legitimate interests.
If we have obtained your consent to process your data, you have the right to withdraw that consent, at which point we will no longer be able to process your data – if that is the only condition which we are relying upon to justify the processing. Please note, however, that in cases where we have a legal obligation, we may need to continue to process your data regardless of consent.
Similarly, if you choose not to consent to our processing of personal data it may be the case that we would no longer be able to fulfill our contractual obligations and would have to effectively end our relationship – for example if a prospective employee declined to allow their data to be sent to a third-party payroll provider, then we would not be able to make salary payment.
Your personal data will only be shared in accordance with data protection laws where deemed necessary and where third parties are providing services to as part of our ongoing services and in order to satisfy our legal and regulatory obligations and/or provision of our ongoing services to clients.
Visitors to our website
People who contact us
Contact information obtained by us as part of business related discussions or data relating to existing client relationships may be held as part of our records for as long as deemed necessary in order to further prospective and ongoing client relationships. We use this information to keep in touch and provide you with our newsletters. When we contact you, you will always be given the opportunity to have your contact details removed from our mailing list.
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with company policy.
Over the Telephone
We do not record telephone calls; however message are stored securely and with limited access given to specific employees and deleted after 28 days.
Job applicants, current and former employees
When individuals apply to work with us, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held and destroyed 12 months after the recruitment exercise has been completed. We may retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Once a person has taken up employment with us, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once employment with us has ended, we will retain the file for 7 years in accordance with the requirements of our retention schedule and then delete it.
We are committed to keeping your personal data safe and secure. Access to personal data is limited to those employees who require it for a purpose.
Where we use a third-party service we only share the personal data that is required to deliver the service and we require that company to keep your information secure.
Complaints or queries
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
Should you wish to exercise any of your data protection rights, please email firstname.lastname@example.org setting out your concerns/request.
You have the right to complain directly to the Information Commissioner’s Office (ICO) who regulate our use of data.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of MTS’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed.