This Policy lets you know what data we may collect about you, how we use it and gives you information about your rights and how you can get in touch with us.
This notice applies to current and former customers and covers the use of our main website, how we manage our direct marketing activities, how we handle your information when you contact us and other uses of your data.
in accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our customers, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
- Data Protection Principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing is fair, lawful and transparent
- data is collected for specific, explicit, and legitimate purposes
- data collected is adequate, relevant and limited to what is necessary for the purposes of processing
- data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
- we comply with the relevant GDPR procedures for international transferring of personal data
- Types of Data Held
We keep several categories of personal data on our customers in order to carry out effective and efficient processes. We keep this data in secure systems.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers
- bank account details
- tax codes
- CCTV footage
- Lodgement details
- Contract details
- Routes and schedules.
- Collecting your Data
You provide several pieces of data to us directly during the contract set up period and subsequently upon the start of your contract.
Contract data is kept in secured files or within the Company`s IT systems.
- Lawful Basis for Processing
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the contract we have with you. The lawful basis for customer contracts is that “processing is necessary for the performance of a contract with the data subject or to take steps into a contract.
- Special Categories of Data
Special categories of data are data relating to your:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership
- genetic and biometric data.
We carry out processing activities using special category data:
- for the purposes of equal opportunities monitoring
- in our sickness absence management procedures
- to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
- Failure to Provide Data
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you. This could include being unable administer contractual benefits.
- Who we Share your Data with
Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons: for the administration of accounts. For the processing of lodgements.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
- Protecting your Data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
- Retention Periods
We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Where you are a customer, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 12 months.
Where you are a prospective customer and you have expressly consented to us contacting you, we will only retain your data
(a) until you unsubscribe from our communications; or, if you have not unsubscribed
(b) while you interact with us and our content
(c) for 12 months from when you last interacted with us or our content.
In the case of any contact you may have with our customer services team, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require Pivotal to hold certain information for specific periods other than those listed above.
- Automated Decision Making
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
- Customer Rights
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
More information can be found on each of these rights in our separate policy on employee rights under GDPR.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
- Making a Complaint – GB and NI
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
- Making a Complaint – ROI
If you think your data rights have been breached, you are able to raise a complaint with the Office of the Data Protection Commissioner. You can contact the ODPC at Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois or by telephone on +353 57 8684800 or +353 (0)761 104 800 or Lo Call 1890 252 231 or email firstname.lastname@example.org.
Pivotal have a dedicated Data Protection Officer and for any queries please email email@example.com