Data controller and data protection officer
Clevertouch/Sahara AV/Sedao as an organisation is a data controller and specifically, Mr. Nigel Batley a company director, is Clevertouch’s/Sahara AV’s/Sedao’s nominated Data Controller. Mr. Batley can be contacted by email at email@example.com or telephone number +44 (0)20 8319 7700. Clevertouch/Sahara AV/Sedao have reviewed the requirement to appoint a Data Protection Officer but have decided that this is not necessary.
On what basis do we collect and process your data? (known as lawful processing)
We collect information about you our customers (and your own customers) or prospective clients in order to process your order, manage your account and if you agree by consenting at point of collection, to email you about other products and services. We also collect information when you voluntarily complete customer surveys and provide feedback. The lawful basis on which we process your data is in the legitimate interests of Clevertouch/Sahara AV/Sedao. In identifying this lawful basis, we have conducted a ‘Legitimate Interest Assessment’ in order to be satisfied that the interests of Clevertouch/Sahara AV/Sedao do not override with your own legitimate rights and freedoms.
We also collect personal data during our recruitment process which is used for the purpose of pre-employment checks, ongoing employment, and providing remuneration. This personal information is held and processed on our payroll system. Once again, we have identified the lawful basis as in the legitimate interest of Clevertouch/Sahara AV/Sedao.
The personal data we collect is provided as a contractual requirement. The possible consequences of not providing the required data are that we may not be able to either offer employment or engage commercially in the supply of audio visual products.
In relation to the legitimate interests that determine our lawful processing, Clevertouch/Sahara AV/Sedao undertakes the processing of personally identifiable information in relation to employees to ensure suitability for employment and to discharge any statutory responsibilities in relation to right to work, residency and HMRC requirements.
Both Clevertouch/Sahara AV/Sedao and the employee benefit from this processing activity as it provides safeguards for Clevertouch/Sahara AV/Sedao and facilitates employment for the Data Subject. If processing this data were not permitted, then the company could not operate and provide goods and services as well as not being able to offer employment opportunities. The data collected will not be used for any unlawful or unethical purpose.
The processing of customer data is undertaken in order to engage commercially and offer the most appropriate audio visual products. In addition, we maintain an oversight of our customers to continue our support which requires contract. Clevertouch/Sahara AV/Sedao and the customer benefit from this processing activity as it provides opportunities to establish and sustain commercial relationships and to provide the most focused advice for the benefit of the customer. If processing this data were not permitted, then the company could not operate and provide products and associated support.
Clevertouch/Sahara AV/Sedao has conducted a Legitimate Interest Assessment and conclude that there is a justifiable necessity to process personal data under this purpose and that the balance of rights of the Data Subject and Netvector has been reviewed. In our opinion, Clevertouch’s/Sahara AV’s/Sedao’s interests do not override that of the data subjects.
Clevertouch/Sahara AV/Sedao does process some health data in the managing the employment of our staff. We have identified that Legitimate Interest is the lawful basis for this processing as consent between employee and employer cannot be considered as freely given.
Categories of Data
Clevertouch/Sahara AV/Sedao processes non-sensitive data.
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website. We will use the persistent cookies to: enable our website to recognise you when you make subsequent visits to this website.
Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.
Any personal data we collect, hold and process is retained both within our own company systems and that of our 3rd party logistics and support providers.
Personal Data is not transferred outside of the UK.
The data we collect directly from you is the minimum we require to facilitate the lawful processing described above. Personally Identifiable Data placed on our internal systems will be deleted as soon as practicable after termination of a commercial contract between us but taking account of any warranty or support requirements.
Personal data collected and processed for HR and Finance purposes will be held for the maximum time as determined by any legal requirement, such as payroll and finance records. We will retain HR data for a period after termination of contract to ensure the integrity of records, should any dispute be lodged in relation to employment at Clevertouch/Sahara AV/Sedao.
Your rights as a data subject
The regulations provide a number of rights to you as the Data Subject. Clevertouch/Sahara AV/Sedao is committed to upholding those rights and those applicable to the personal information we collect and process are listed below. In addition to these rights, you have the right to escalate any concern to the Supervisory Authority, which in the UK is the Information Commissioners Office https://ico.org.uk. A full and detailed explanation of all rights can be found at https://ico.org.uk/for-the-public/
- Right of Access – you have the right to know what personal information is held, by whom and why. You can send a Subject Access Request to see what personal information and any supplementary information relating to you is held by us. We will provide you with the information we hold within one month of your request, unless the provision of that information is particularly complex. In which case, we may extend the deadline by a further two months. This information will be provided free of charge unless you require multiple copies of the same information, in these circumstances, we retain the right to charge a reasonable administrative fee.
- The Right to Rectification – If the information we have collected and processed is inaccurate or incomplete, you have the right to have it rectified. We will respond to your request for rectification within one month, unless the request is complex or multiple.
- Right to Erasure – You have the right to have your personal data erased and to prevent processing in some specific situations, these include:
- Where personal data is no longer necessary regarding the purpose for which it was originally collected
- When you withdraw consent
- When you oppose the processing and there is no superseding legitimate interest for continuing the processing
- If the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- If the personal data must be removed in order to comply with a legal obligation
- If the personal data is processed in relation to the offer of information/ society services to a child.
- Right to Restrict Processing – If you contest the accuracy of the personal data we hold, we will restrict the processing of your data until accuracy is verified. The restriction of processing can occur for other reasons too, such as if you require us to retain your data in the advent of a legal claim.
- Right to Data Portability – You have the right to move, duplicate or transfer your data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
You also have the right to lodge a complaint with the UK’s supervisory body, The Information Commissioners Office www.ico.org.uk
Automated decision making
Clevertouch/Sahara AV/Sedao does not conduct any profiling or automated decision making.
- You can write to Clevertouch/Sahara AV/Sedao at this address: Clevertouch/Sahara AV/Sedao, Sahara Presentation Systems Limited, Europa House, Littlebrook DC1, Shield Road, Dartford, Kent, DA1 5UR
- You can telephone Clevertouch/Sahara AV/Sedao on this number: +44 (0)20 8319 7777
- You can email Clevertouch/Sahara AV/Sedao by using this link: firstname.lastname@example.org / info@saharaAV.com / email@example.com