Looking after the personal information you share with us is important. This is where we tell you how and where we use your personal information and how we look after it.
At Banham we collect personal data:
- To enable us to deliver the services you have requested, such as; key registration, the maintenance and servicing of your security system, monitoring of your security system, keyholding and alarm response
- To meet any regulations and requirements from our regulatory bodies, such as the NSI and SIA
- To analyse what products and services are popular and how we can improve our product and services offerings
- To talk to you about the other services and products we offer that may be of interest to you
To make is easier for you to read this policy, we have broken it down into the following sections:
- About this policy
- What information we collect about you and how we use it
- Why we collect data
- Children’s Data
- Updating your personal information
- Who we share data with
- Transfer outside the European Economic Area
- Google Analytics
- Job Applicant Privacy Notice
- Who we are
- Your right to complain
- Changes to the privacy promise
1. About this policy
- The protection of your privacy and personal information is important to us. We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us.
- We will respect your privacy. You should receive marketing emails only from us and, if you agree, from other organisations we have carefully chosen. We will make sure that the boxes you need to tick if you are happy to receive marketing are presented clearly and at an appropriate time.
- We will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it.
- We will collect and use your personal information only if we have your permission or we have sensible business reasons for doing so.
- We will minimise the amount of information we collect from you to what we need to deliver the product and services you have requested.
- We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
- We will use personal information only for the purposes for which it was originally collected, and we will make sure we store it safely, and delete it securely.
- Our websites are accessible via the internet. Please remember that if you post any comments or links on any of our sites that they can be read and accessed by anyone and everyone.
If we, our service providers, or our commercial partners transfer any information out of the European Economic Area (EEA), it will only be done with the relevant legal instruments or permissions being in place.
2. What information we collect about you and how do we use it
We may collect information on you:
- when you ask us to deliver a service or product
- when you contact us for information
- when you book an appointment
- when you download our app
- when you use the website
- through cookies
- if you choose to reveal information in postings
- if you complete your details on customer feedback surveys or research questionnaires, and
This personal information may include but is not limited to the following information about you:
- your name (including your first names and surname);
- your email address;
- other details about you that you or others provide to us; and
- sensitive personal data but only where you have provided your explicit consent for the collection of and use of such sensitive personal data
3. Why we collect data
We have to tell you the reason for collecting your information – and this is called the legal basis for processing.
- Where you provide information in the course of a Contract Agreement i.e. to service your security system, we process your data under Contract, so your data is necessary to fulfil the service you are paying for.
- Any additional contact, i.e. telling you about another product or service closely related to the product or service you have contracted is managed under legitimate interest.
- When you sign up to receive more information about our products and services, we manage this under consent because you told us you wanted to receive it.
When you buy Banham products and services, we have a legal obligation to keep a record of the transaction, not least to be able to provide you with an appropriate bill afterwards. We also keep a record of what we have installed to be able to provide you with technical assistance when required.
We will always make it as easy as possible for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the service you have requested.
From time to time we may use some elements of the data you supply to target the messages we send you. For example, you may be interested in upgrades to our products and services.
None of this information is collated by wholly automated means and the rights and freedoms of the data subject are safeguarded by suitable measures.
How long do you hold on to my data?
Because we collect data for a wide range of purposes, we do not have a singularly defined retention period. For each individual product and service we define a carefully assessed timeframe within which we retain your data. For example, we are obliged by legislation to keep details of any financial transactions for seven years. Under NSI regulations, if we monitor your security system, we are required to keep some information for up to 3 years.
After this, data is managed to ensure that it is either erased from our system, minimised and retained for legal reasons or pseudonymised and retained on a global suppression list to ensure that you do not receive unwanted messaging from us.
4. Children’s Data
We do not knowingly collect or store any personal information of children under the age of 16, except within the context of the provision of our services.
5. Updating your personal information
Under current data privacy legislation, you have the right to rectify, erase or restrict the processing of your data without undue delay. You may also request access to the data we hold on you. Please note, that in the context of the services we provide, some data cannot be erased or rectified due to current legal obligations.
We are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you want to see the information we hold about you (also known as a subject access request) or make a change to your data or the ways in which we contact you, please send an email to firstname.lastname@example.org. We may need to verify your identity before any data is amended or released.
6. Who we share data with
We do not and will not, sell or share your information at any time to anyone else for marketing purposes.
Generally speaking, we don’t share your information with anyone else because your data and security is extremely important to us and customer confidentiality is key. If we need to for any reason, we will let you know in advance, unless someone in a legal capacity tells us we can’t.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards.
The Data Protection Officer role is provided to Banham by IG-Smart Ltd, https://ig-smart.com/ who will liaise on our behalf with the Information Commissioners’ Office.
7. Transfer outside the European Economic Area
We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA or countries deemed adequate by the EDPB.
If we need to send any information outside of the EEA, it will only be done with the proper legal protections or permissions being in place.
Cookies are packets of data that sit on our website, in some cases to make it work, and in some cases to add additional services. For more information about cookies, how to look after them, even how to turn them off, please visit our page on cookies.
9. Google Analytics
We use Google Analytics on our sites for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link https://tools.google.com/dlpage/gaoptout
11. Job Applicant Privacy Notice
Our job applicant privacy notice is available here.
12. Who we are
Banham Patent Locks Ltd is a company registered in England with the number 0457812. Our address is 20 Thornsett Road, London, SW18 4EF. We are registered as a data controller with the Information Commissioner’s office – our registration number is Z628108X.
If you would like to contact Banham, please email email@example.com or contact us by telephone on 020 7622 5151.
13. Your right to complain
If you are not satisfied with the way we have handled a request regarding your data, you have the right to lodge a complaint with the supervisory authority – details of which are given below:
Information Commissioner’s Office
Telephone: +44 303 123 1113
14. Changes to our privacy promise
If we make changes to this document we will show you what they are here. If these changes are significant, we may also choose to email relevant individuals with new details. If we are required by law, we will obtain your consent to make these changes.
Changes to this policy by date
May 2018 – New company privacy promise created.
August 2019 – Privacy promise updated.
February 2020 – Privacy promise updated.
March 2021 - Job Applicant Privacy Notice added.