Last updated: May 2018
We understand how important your personal data is and are committed to protecting and respecting your privacy.
‘Personal Data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers (such as an account number or your national insurance number), location data or online identifiers. Personal data can be held electronically or in certain paper records.
The General Data Protection Regulation (GDPR) regulates the processing of personal data. The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations that handle personal data must adopt. This Privacy Notice is issued in compliance with GDPR and seeks to explain:
- Who we are;
- All website addresses covered by this Privacy Notice;
- How we collect your personal data;
- Why we collect your personal data;
- How long we hold the personal data;
- The conditions under which we may share it with others;
- Overseas processing;
- How we keep your personal data secure;
- Your personal data rights and how to exercise them;
- Useful information; and
- Any further questions.
1. Who we are
Charter Systems Limited (CSL) is one company within the Equiniti Group. Our main business is software services. Our registered address is 2nd Floor Ashley Park House, 42 -50 Hersham Road, Walton on Thames, Surrey KT12 1RZ and our ICO registration number is: Z2258990.
CSL is a ‘Data Controller’. This means that we are responsible for deciding how and why we hold and use personal data about you.
In this Privacy Notice, ‘we’, ‘us’ and ‘our’ will always mean CSL, as Data Controller.
If you have any questions about our portal service, please contact us:
By phone – 01932 250000 (between 08:30hrs and 18:00 hrs)
By email – email@example.com
2. All website addresses covered by this Privacy Notice
- Covert Management Solution – www.charter-systems.co.uk
3. How we collect your personal data
We may collect and process the following personal data about you:
Information you provide to us
- By logging into our website(s);
- By corresponding with us by phone, e-mail or otherwise with queries about our portal service.
Information we collect about you
- From your employer to set up your access log in via email or telephone;
It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this. Please let us know as soon as anything needs updating or correcting.
Special types of data
The law and other regulations treat some types of personal information as special. We will only collect and use this information if the law allows us to do so. Special types of data are:
- Criminal convictions and offences;
- Genetic and bio-metric data;
- Health data including gender;
- Racial or ethnic origin;
- Religious or philosophical beliefs; and
- Trade union membership.
4. Why we collect your personal data
In the table below we demonstrate why and how we use your personal data as well as providing the legal reasons which we rely upon.
Under Data Protection legislation we must always have a legal reason for processing your personal data. One of the legal reasons is when we use your personal data for our legitimate interests, this is usually when we have a business reason. However, we must always ensure that we take your interests into consideration too, and ensure that the use is fairly balanced. We tell you below when we rely on legitimate interests and what our legitimate interests are.
Type of processing
Purpose of the processing
Lawful basis for the processing of personal data
|Provision of services, including the administration of your online account||
To manage and operate your online account with us to facilitate the provision of services, this includes retaining records of your visits and keeping your online account records up to date.
To respond to any data rights that you invoke.
To keep our websites and portals secure and permit you safe access to our services.
Our legitimate interests, such as the proper administration of our service and business, for example:
If you choose not to give personal information
We need to collect personal information required by law or under the terms of service you have elected to use. If you choose not to give us the personal data we need, it can mean that we have to cancel or decline a service that you request or have with us. So that you know what information is optional, we make it clear at the time we collect your personal data.
5. How long we hold your personal data for
Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data. We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.
We will retain your personal data for 18 months after the last active login and delete your details 6 years after your last active log in.
6. The conditions under which we may share your personal data with others
The personal data we hold about you is confidential, and we will only share your personal data to enable us to deliver our product(s) or service(s), examples are as follows:
- Your employer
- Our professional advisors, for example, our lawyers and technology consultants, when they need it to provide advice to us; and if necessary
- Fraud prevention agencies who will use it to prevent fraud. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, can be obtain by contacting the Equiniti Data Protection Officer using the details noted below; and
- Regulators and supervisory authorities e.g. Information Commissioner’s Office (ICO), Credit Industry Fraud Avoidance System (Cifas) – as part of our legal obligations;
- Where the law requires or permits disclosure, or there is a duty to the public to reveal it;
- When we need to defend or exercise our legal rights or those of a third party;
- Police and other law enforcement agencies for the prevention and detection of crime and where a valid permission is applicable;
- As a result of a court order or other regulatory instruction; and
- Our insurers and insurance brokers where required for underwriting our risks and as part of ongoing risk assessments
We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. At all times, we take steps to ensure your privacy rights continue to be protected as per this Privacy Notice.
7. Overseas Processing
CSL does not share any personal data overseas in relation to the Covert Management Solution.
8. How we keep your personal data secure
We understand how important your personal data is to you and we take its security very seriously.
Where we have given you (or where you have chosen) a password or unique identifier (PIN) which enables you to access certain parts of online services, you are responsible for keeping this password / PIN confidential, along with any username. We will never ask for your full password or PIN, and you must not divulge your full password to us or anyone else. We recommend that any password or PIN you set is not easily guessable, and changed frequently.
Because we cannot guarantee the confidentiality of personal data sent on the internet you should never send your login details via email.
If you ever receive a communication from us by post, email or by phone that you are concerned it is not genuine, please contact us using the contact details in Section 11.
You must immediately inform us if you become aware, or suspect, that someone else has knowledge of your account details.
If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of Get Safe Online, which can be accessed at www.getsafeonline.org.
9. Your personal data rights and how to exercise them
You have rights in respect of the personal data that we hold about you. They include the right to request a copy of the information that we hold about you, to know about any automated decisions that are made about you and to change your marketing preferences at any time. Details about all of your rights are provided below.
Some of these rights are conditional and depend upon why we are processing your personal data. This means that we cannot always be able to respond to your request in the way that you want. For example:
- If you ask us to erase your personal data and we are processing the information because we are required to do so because of a legal requirement, we will not be able to delete your personal data; however,
- If you ask us to erase your personal data and we are processing the information because you provided us with consent (for example as part of a survey response), we will be able to consider and respond to your request.
|The right to be informed about how we use your personal data.||This Privacy Notice provides you with the details on how we use and process your data.|
|The right of access to a copy of any personal data processed about you, together with certain additional information.||If you request to see your personal data, your initial request will be free of charge; subsequent requests may attract an administration fee. The additional information includes details of the categories and recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.|
|The right to request us to rectify or update it.||This will be relevant where the personal data we hold is or has become inaccurate or incomplete, taking into account the purposes of the processing. Please explain why you consider the data inaccurate or incomplete.|
|The right to request us to erase your personal data in certain circumstances.||The circumstances when erasure can apply include when we no longer need it to meet a lawful basis for processing unless that basis is consent and you withdraw your consent or you object to the processing or the processing is unlawful.
However, certain exclusions apply – where the processing is necessary for compliance with a legal obligation or to establish, exercise or defend legal claims.
|The right to request us to restrict processing it.||This request can be used to stop us processing your personal data: if you disagree over the accuracy of the personal data until we have verified the data; the reason for processing; or if you wish us to retain your personal data for longer than our retention period, e.g. to establish, exercise or defend a legal claim.|
|The right to request a copy of your information for data portability purposes.||If you have provided personal data to us under contract or because you consented to the processing and use the data by automated means, then you have the right to instruct us to transmit that personal data to you or another data controller in a machine-readable format.|
|The right to object to us processing your personal data.||You have a right to object to us processing your data where we are processing it for the purpose of legitimate interests.
You can also object to direct marketing communications from us about products, offers, competitions, or services and any profiling that we can perform in relation to direct marketing. You can do this at the point of data collection, through the use of any opt-out functionality on text and emails, via your preference centre or by contacting the helpline service.
You can update your marketing preferences at any time through the use of the opt-out functionality.
You have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing before the withdrawal.
If you would like to receive the marketing described above, please ensure you have indicated your preferences accordingly.
|Rights related to decisions based solely on automated processing.||Where this processing produces legal effects or significantly affects you, you can object to this processing unless the processing is necessary as part of our contract, or is required by legislation.|
|Right to lodge a complaint with a supervisory authority.||If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection team who will investigate the matter and report back to you.
If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country. In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation. They can be contacted by email: firstname.lastname@example.org, post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113.
10. Useful information
10.1 – Use of ‘cookies’
10.2 – Links to other websites
Our websites can contain links to other websites run by other organisations, or other Equiniti Group companies. When you are on another website, we encourage you to read their privacy policies as they will take precedence over this Privacy Notice.
10.3 – Changes to this Privacy Notice
We review our use of your personal data regularly. In doing so, we can change what personal data we collect, how we keep it and what we do with it. As a result, we can change this Privacy Notice from time to time to keep it relevant and up to date.
We will endeavour to alert you to these changes so that you can check you are happy with it before proceeding any further. Please look out for notices from us alerting you to these changes. If you use our portal and see such an alert, please take a moment to ensure that you’re happy with any changes.
By continuing to use our products and services, you will be bound by this Privacy Notice.
However, we will also tell you of the changes where required by law to do so.
This policy was issued on 24.05.18. If you require copies of previous versions of the Covert Management Solution Privacy Notice, please contact us using the contact details in section 1 above.
11. Any further questions about this Privacy Notice
We hope that this Privacy Notice has been helpful in setting out how we handle your personal data and your rights to control it. If you have any questions that remain unanswered, please contact us in the first instance using the contact details in section 1 above, alternatively you may contact our Data Protection Officer:
- By email at DPO@equiniti.com,
- By post at Data Protection Officer, Equiniti, Highdown House, Yeoman Way, Worthing, BN99 3HH, or
- By telephone on 0333-207-5962 (from UK) and +44 121-415-0196 (from overseas).
(Lines are open 8.30am to 5.30pm (UK time), Monday to Friday (excluding public holidays in England and Wales).