Comserv(UK) Ltd is committed to ensuring that your privacy is protected. This policy describes how and why we collect, store and use personal data and provides information about individuals’ rights. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1. INTRODUCTION
In this Privacy Policy, “we”, “us” and “our” refer to Comserv (UK) Ltd, 10 Downley Road, Havant, Hants PO9 2NJ, Company Registration Number 5193429. Comserv (UK) Ltd delivers responsive repairs and planned projects for local authority/councils and housing associations. This Privacy Policy therefore applies to all personal information obtained in the delivery of our housing maintenance, planned projects and support services.
We are committed to ensuring that the personal data we collect and use is appropriate for this purpose and does not constitute an invasion of an individual’s privacy. This section sets out further details of the types of personal data we collect in different circumstances and how we use it.
2. WHAT INFORMATION DO WE COLLECT?
The information we collect, store and process about you is received from different sources:
Visitors to our website
Your personal data including your name, email address, telephone number and other contact information will be collected if you visit our website. We may also ask you for information when you have reported a problem with our website.
We may collect details of your visits to our websites including traffic data, location data, weblogs and other communication data as well as details of the resources that you access.
The information we hold about you is used in the following ways:
• To ensure that content from our websites is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us.
• To carry out our obligations arising from any contracts entered between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
Our website may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A copy of our Cookie Policy can be found here.
Customers and related individuals
We receive personal information from our customers (e.g. Local authorities/councils, Housing associations and tenants) and related individuals which we collect, process and store in order to deliver our maintenance services effectively. The data we receive or collect may include:
• Your name, home address and contact details (including your telephone number, email address)
• Alternative contact details where required and provided to deliver the maintenance service (i.e. name, relationship and home and telephone numbers)
• Photos taken with your consent for publicity and training purposes
• Your feedback and contributions to questionnaires and surveys about the services we offer and deliver to enable us to continuously improve
• Your complaints, compliments or concerns about the service we provide
• Other information reasonably required in order to effectively deliver maintenance services to our clients and customers. This may include Special category data, which is data that is more sensitive so needs more protection. Where necessary and appropriate, we may collect special category information in order to provide our services and to comply with our legal obligations. Some of the special category information we collect within the scope of this privacy policy may include information on a health condition, disability, vulnerability or other information that we would reasonably need to be aware of in order to access your property, as well as to tailor our services to meet our customer needs and ensure the health and safety of our staff in delivering maintenance services.
Suppliers and third-party service providers (individual contractors)
We may collect personal data including your name, email addresses, telephone numbers and other business contact information for the purposes of receiving services or quotations, managing relationships, providing services to our customers and operating our business.
Media
Personal data including your name, email address, telephone number and other business contact information may be collected directly from you, any organisation you represent, marketing or PR agencies or from databases and platforms which you have signed up to.
We may use the personal data we collect for the purposes of circulating press releases, statements or market commentary or inviting you to attend events or to meet or speak with Comserv personnel.
Job Applicants
If you register interest in applying for a vacancy with comserv or submit an application for a vacancy, we will collect your name and contact details including your address, email address and telephone number. More detailed personal data may also be collected where you are the subject of a vetting process which may include details of your employment and education history, references, professional memberships and qualifications, criminal records check results, DVLA details and proof of identity documents.
Information we collect will be used by us to process and progress your application and to complete our induction processes should you go on to be employed or engaged by us.
Comserv Employees
We may use and disclose the information we collect in such manner as necessary to enable us to carry out our business and to receive the services being provided. This includes the use of personal information in connection with payment and meeting contractual and health & safety legal requirements.
Further information regarding the collection and use of personal data of employees is provided as part of our induction process and can be obtained at any time by contacting the HR team on .
3. OUR LEGAL BASIS FOR COLLECTING DATA
We will only process personal data where we have a lawful basis on which to do so. Our main legal basis for processing personal data is where it is necessary for the purposes of the legitimate business interests pursued by Comserv or by a third party to process your information. We can do that so long as we do not interfere with your fundamental rights or freedoms.
This would include, but is not limited to:
• To process and complete any maintenance job, work item or request or deliver other services to you
• To respond to your query, complaint, issue or any matters raised with us or via one of our agents
• To process payments owed to us and/or relating to or resulting from the delivery of our services (especially where our contract is with a third party such as a Local Authority or Housing Association and not with you as an individual)
• For internal business processing and operations including but not limited to quality assurance, management information, audit, governance and financial processes
• To develop, improve and manage our website
• To request feedback or customer satisfaction information relating to our performance in service delivery to assist us to continuously improve and
• To enable us to provide access to our offices and corporate systems
The other reasons we can rely upon to process your personal information under GDPR is as follows:
• Where we are under a legal obligation or an obligation under a contract to process/disclose the information (e.g. to respond to claims, accident investigations and other legal procedures where we are required to provide information);
• Where we need to protect the vital interests (i.e. the health and safety) of you or another person; and/or
• With your consent (i.e. agreement) to us processing your personal information. Under the GDPR, consent is a legal basis for processing personal information. You can withdraw your consent at any time.
• Some personal information is treated as more sensitive (e.g. information about health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexuality, generic and biometric data) . The legal basis for processing these special categories of personal information is more limited. To lawfully process special categories of personal data, we must identify a lawful basis for the processing and meet a separate condition for the processing. The basis we can use these are:
a. With your consent;
b. Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
c. Where you have already made your personal information public;
d. Where we or another person needs to bring or defend legal claims;
e. Where we need to participate in a government or local authority led public health response; and/or
f. Substantial public interest grounds.
We will only use your information for the purpose(s) it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or where there is a legal requirement for us to use that information. We may process your information without your knowledge or consent only where this is required or permitted by law.
4. SHARING/TRANSFERRING YOUR DATA
We may pass your personal data on to third-party service providers Comserv (UK) Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Comserv’s procedures. If we wish to pass your sensitive data onto a third party we will only do so once we have gained your consent, unless we are legally required to do so.
Additionally, we may on occasion transfer to, process and store the information we collect about you in countries other than the country in which the information was originally collected. These countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect the information as described in this Privacy Notice.
5. HOW LONG WILL YOUR INFORMATION BE KEPT FOR
Comserv takes reasonable steps to ensure the information we process is reliable for its intended use, is accurate, up-to-date and complete, and is limited to the information required to carry out processing for the purposes described in this privacy statement. We retain the information for as long as necessary to fulfil the purposes for which we collect it, except if otherwise required by law.
6. YOUR RIGHTS AS A DATA SUBJECT
At any point while we are in possession of processing your data, you the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing
• Right of portability – you have the right to have the data we hold about you to be transferred to another organisation
• Right to object – you have the right to object to certain types of processing
• Right to object to automated processing, including profiling – you also have the right to object to the legal effects of automated processing or profiling
• Right to judicial review – in the event that Comserv refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as detailed in Section 7.
All of the above requests will be forwarded on should there be a third party (see section 4) involved in the processing of your personal data.
7. COMPLAINTS OR QUERIES
If you are concerned about any aspect of how we handle your personal information, please do contact us as detailed below in section 8.
Alternatively, in the event that you wish to make a complaint or are not satisfied with the responses you have received from us after making a request, you have the right to lodge a complaint directly with the UK’s supervisory authority, the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. The ICO website is available at: www.ico.org.uk
8. HOW TO CONTACT US
Our Data Protection team can be contacted by email at admin@comserv-uk.com or via post to: Data Protection Lead, Comserv (UK) Ltd, 10 Downley Road, Havant, Hants PO9 2NJ
9. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy was last updated on Monday 3 August 2020. We may change this policy from time to time and future changes will be published on our website.