1.1 In this policy, “we”, “us”, “our” refer to Cowley Security Locksmiths and “you” and “your” refer to our customers.
1.2 We are committed to protect the private data we receive and store from you and respect your rights under the General Data Protection Regulation.
1.3 This policy applies when we receive your data and we are acting as “data controller” and when we process it and we are acting as “data processor”.
1.4 For more information about us and how you can contact us, please see Section 10.
1.5 Credit: This document was created using a template from the Master Locksmiths Association that is made available to members only.
2.Origin of our data
2.1 We only collect information directly from our customers (you) for schedule, key duplication or financial purposes, before a job (when the customer gets in contact with us), or at the end of a job, when details such as name and address are requested to create a VAT invoice.
3.Processing your data
3.1In this section we explain how we use your personal data.
3.2 Your data will be used as correspondence data ([Cowley Security Locksmiths] may contact you by e-mailing or calling to give you updates on the service required or to send you a written quote). The legal basis of processing the correspondence data is the legitimate interest to perform a service, requested by you from us.
3.3Your data will be used as transaction data and it may be used for financial records such as VAT invoices and it will be kept for 6 years. The legal basis of this processing are the “legal obligations” to which Cowley Security Locksmiths is subject.
3.4The data related to the security keys, will be only used to confirm your identity if you request us to create a copy of the key.
4.Sharing your details
4.1 Cowley Security Locksmiths does not share your private data with any other third party.
5. Storing your data
5.1 This section explains how we store your private data and for how long.
5.2 Your private data may be printed and secured in our locking filing cabinets/cupboards. The cabinets/cupboards are placed within our alarmed secured premises.
We store our correspondence/schedule data for one year for the legitimate purpose of keeping a record of the job our company carries out.
5.3 Your private data may be stored electronically on our computers that are based in the UK. Our computers are protected by password and anti-virus program, and they can only be accessed by our staff members.
5.4 Your details related to the security keys are stored in a locked filling cabinet/cupboard that can be accessed only by the staff members.
6. Deleting your data
6.1 This section explains how we delete/destroy your data once is no longer needed. For more details about the length of time we store your data please see Section 3 (3.3) and 5 (5.2).
6.2 Once your private data is no longer relevant/needed Cowley Security Locksmiths will permanently delete the electronic files.
6.3 Once your private data is no longer relevant/needed Cowley Security Locksmiths will periodically hire a secure document shredding company, that complies to the GDPR, to destroy the documents.
7. Data breaches
7.1 Cowley Security Locksmiths has standard procedures to protect your details against data breaches such as passwords for electronic files, that are periodically changed, alarms and secure filing cabinets for physical documents. For more details on how we securely store your documents please see section 5.
7.2 We back-up your data by creating an electronic copy of each document that is securely stored on our computer based in the UK, that is protected by password and anti-virus program.
7.3 Cowley Security Locksmiths understands the legal requirement to report a data breach to ICO (Information Commissioner's Office) in maximum 72h hours from the event. We also commit to inform every person that has been affected by the data breach.
8.1 We may update this policy in order to improve our data management.
9. Your rights (GDPR rights of the natural person)
9.1 This section explains the rights, you have, as a data subject, in relation to your personal information.
9.2 To be informed about how, why and on what basis that information is processed.
9.3 To obtain confirmation that your information is being processed and to obtain access to it and certain other information, by making a subject access request— your request will be answered in maximum 7 working days.
9.4 To have data corrected if it is inaccurate or incomplete.
9.5 To have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (the right to be forgotten).
9.6 To restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but you do not want the data to be erased), or where the employer no longer needs the personal information, but you require the data to establish, exercise or defend a legal claim.
9.7 To restrict the processing of personal information temporarily where you do not think it is accurate (and the employer is verifying whether it is accurate), or where you have objected to the processing (and the employer is considering whether the organisation’s legitimate grounds override your interests).
9.8 If you wish to exercise any of the rights in paragraphs, please contact the data protection officer on firstname.lastname@example.org.
10. Cowley Security Locksmiths details
10.1 Our registered office is at
146 Colne Road, Twickenham, Middlesex, TW2 6QS
10.2 You can contact us:
a) by post to the address above.
b) by e-mail to email@example.com
c) by telephone 020 8894 1212