Barclay Communications Privacy Notice
Our Privacy Notice
Barclay Communications is a company registered in Northern Ireland under company number NI040916 and operating from Grove House, 145-149 Donegall Pass, Belfast, BT7 1DT.
In order to comply with our responsibilities under the General Data Protection Regulations 2016 and the Data Protection Act 2018, we have an obligation to ensure we are clear with how your data is handled while in our possession.
The privacy of our clients, representatives & users and their data matters to us and we want to ensure they are clear on how we will use it. This policy provides details on what information and data we collect from them in relation to providing our services and activities, why we need it, how we will use it, how we will take care of it, who we will share it with and details of the data subjects’ rights in relation to our processing of this data.
We provide the following business activities/services:
- Mobile Phone Services & Hardware
- Landline Services & Hardware
Data Protection Principles
This policy has been developed to help Barclay Communications be compliant with the Regulations. The regulations set out principles which any party handling data must comply with. These principles are that all data shall be:
Processed fairly and lawfully
Held only for specified purposes and not used or disclosed in any way incompatible with those purposes
Adequate and relevant
Accurate and up-to-date
Not kept for longer than is necessary for the purpose it was collected
Processed in accordance with the rights of data subjects
Not transferred outside the European Union
How will we collect information from you?
In order to provide our services and activities, we must collect certain information. The type and level of information we collect will depend on which of our services are required. We will collect the information we require to provide these services through general conversations, online forms, telephone conversations, email, sharing of documents (photocopies/email/fax/post) and other forms of communication which are needed to enable us to provide our services.
We may also either during the provision of our services or before providing any of our services need to request or be provided with information by 3rd parties. You will be informed should we need to contact any 3rd party to request any information required.
What information will we collect from you?
The information we will need to collect from you will depend on the services you require from us and what information we will need to ensure the full provision of those services. The information collected will include:
- Email Address
- Contact number(s)
- Date of Birth
- Proof of Identity
- Billing Information
We may also need to collect additional specific information depending on the service you require. The information collected and needed will depend on the type of service you require and not all of the information detailed below may be required.
- Data Usage
- Minutes Used
- Texts Used
- Call Information
Not all of the data we collect is personally identifiable information.
What is our legal basis for processing your information?
Under the regulations, we may only use your information if we have a lawful basis for doing so. This means either we will have your consent, a contractual, statutory or legal obligation to process the information in our possession.
Once we are engaged for any of the services we will ensure you are aware of how we will use the data and information you provide us.
How will we use the information you provide to us?
The information we collect from you will be used to:
- Deliver our services as required by the customer
- Provide appropriate levels of customer service & support
- Maintain our records
- Process automation
- Maintain communications with the client
- Confirm identity and to prevent fraud
- Investigate and deal with any complaints
- Verify any information supplied
- To provide evidence of best practice, statutory and legal responsibilities
- Fulfil any statutory or legal obligation
- To process invoices and payments
Any information you provide us will not be used in any way you have not been informed about until you have been informed and we have your specific consent.
Who has access to your information?
The staff of Barclay Communications will have access to the information you provide to us. The information they have access to is controlled and monitored and they can only access the information required to ensure the services we have been requested to provide are met.
Depending on the service you request from us we may also need to provide access to or share certain information with other mobile networks, service providers, engineers and other 3rd parties as necessary.
Who may we share your information with?
We may need to provide access to or share certain elements of your information with 3rd parties in order to provide certain aspects of our service(s) or to fulfil statutory and legal obligations.
Not all of the information shared will be personally identifiable data. Examples of these 3rd parties we need to share data with include 02 and BT Openreach. This is so we can maintain our service provision and resolve customer service issues.
Client Service Level Agreements and Terms & Conditions
Barclay Communications understands and accepts that during the course of business certain clients will require us as a Company to abide by specific terms relating to the use of their data, how this data is communicated, stored, accessed, it’s security and how it’s disposed of. Barclay Communications will observe these terms at all times and ensure any staff member with access to the relevant data are fully aware of their and our obligations under the Client’s terms. If at any time we feel these terms have been breached or we are unable to abide by them then we will with immediate effect contact the Client to discuss the particulars.
How long will we keep your information?
Barclay Communications has a statutory and legal obligation to keep information for a period of time after it has been used. We will not keep or store any information after it has been used that we are not required to keep under these obligations.
Once information is no longer required it will be erased and removed from our systems in a controlled and secure manner.
How will we protect your information?
We will endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorised access, copying, use, modification, disclosure or deletion.
Our business may change from time to time. As a result, it may be necessary for us to make changes to this policy. We would ask you to review this policy periodically, either by viewing it on our website or making a request for an updated version. This policy was last updated on DATE TO BE CONFIRMED.
The rights of data subjects
The Regulation sets out the following rights applicable to data subjects:
The right to be informed – You have the right to be informed how your data will be collected, what type of data will be collected, how it will be used, how it will be protected, who it will be shared with if it will be transferred outside the EU, how long it will be kept and how you can request copies.
The right of access – You have the right to request copies of the data we hold on you but not on other individuals. We will provide a first copy free of charge but an additional copy will incur a fee.
The right to rectification – You have to right to ask us to rectify any of the data we hold if you believe it to be incorrect. We may ask you for evidence to support any rectifications or changes.
The right to erasure (also known as the ‘right to be forgotten’) – You have the right, in certain circumstances, to have the data we hold on you erased. If we have a legal or statutory obligation to keep the data we cannot erase it, but we will inform you of any instances where this applies.
The right to restrict processing – You have the right, in certain circumstances, to ask us to restrict the processing of your data. If you believe the data is incorrect or being processed unlawfully you may request we restrict the processing without deleting the data.
The right to data portability – You have the right to request copies of the data we hold on you in an electronic or machine-readable format.
The right to object – You have the right at any time to object to how any data we hold on you is processed. Please see ‘Requesting information and complaints’ below for how to contact us.
Requesting information and complaints
Our clients can request details of the information held by Barclay Communications which relates to them or their children. You can do this by emailing our Data Protection Officer, at the relevant email address, email@example.com or by writing to them at Grove House, 145-149 Donegall Pass, Belfast, BT7 1DT.
If at any time a client is unhappy with how Barclay Communications has processed or processes their data, you wish to make alterations to any data which you believe is incorrect, irrelevant, wishes to make an erasure request or wish to stop hearing from us you can raise this issue with our appointed Data Protection Officer, at the relevant email address, firstname.lastname@example.org or by writing to them at Grove House, 145-149 Donegall Pass, Belfast, BT7 1DT.
When you contact us we may ask you to verify your identity. This is to ensure we are providing any information only to the correct individual(s).
If you feel your request was not handled or dealt with correctly by Barclay Communications you may raise the issue with the Information Commissioners Office, you can contact them on 0303 123 1113.