Privacy Policy

Version Explanation

Document versions are identified using the format v{major}.{minor}. Full version history of the document is available by selecting a different version above.

Major Version

The major version number will be incremented where there is a significant or substantive change to the document. This includes, but is not limited to:

• The addition or removal of a clause.
• A change to the substance or requirements of a clause resulting from an updated process, regulation, or other material change.

A new major version will also reset the minor version to 0.

Minor Version

The minor version number will be incremented where changes are made to improve the clarity, readability or understanding of the document without changing its substantive meaning or scope. This includes, but is not limited to:

• Rewording a clause to clarify what it applies to or how it applies.
• Adding examples to further explain the application or interpretation of a clause.
• Making other editorial or explanatory changes that do not alter the substantive requirements of the document.

Acceptance

Acceptance of a document is based on the major version number and is tied to the applicable contract or Statement of Work (“SoW”).

A minor version update made during an active contract or SoW will automatically apply and does not require additional acceptance, provided that the changes do not alter the substantive scope or requirements of the document.

A new major version will require acceptance under any subsequent contract or SoW. An existing contract or SoW will continue to be governed by the major version accepted at the time of agreement, unless otherwise agreed by the parties.

Accordingly, minor version updates may be made during the term of an active contract or SoW without requiring re-acceptance. A new major version will require acceptance as part of any subsequent contract or SoW.

Who

417 Tech Ltd (“we”, “us”, “our”) is a company registered in England and Wales under company number 17118754, with registered office at:

417 Tech Ltd Sparkhouse Rope Walk Lincoln England LN6 7DQ

You can contact us by post at the above address, or by any of the following other contact methods:

Phone: +44 (0) 333 44 44 417

Email: contact (at) 417-tech (dot) com

Information we collect

Staff

We collect or use the following personal information as part of staff recruitment, administration and management:

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Next of kin or emergency contact details
• Performance records (eg reviews, disciplinary records, complaints or disciplinary action)

Salaries and pensions

We collect or use the following personal information as part of managing salaries and pensions:

• Job role and employment contract (eg start and leave dates, salary, changes to employment contract or working patterns)
• Expense, overtime or other payments claimed
• Leave (eg sick leave, holidays or special leave)
• Maternity, paternity, shared parental and adoption leave and pay
• Pension details
• Bank account details
• Payroll records
• Tax status

Customers

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Transaction data (including details about payments to and from you and details of products and services you have purchased)
• Usage data (including information about how you interact with and use our website, products and services)
• Video recordings
• Audio recordings (eg calls)
• Records of meetings and decisions

Lawful Bases

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Staff

Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information as part of managing salaries and pensions are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Customers

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Where we get personal data from

Staff

We only get your personal data directly from you.

Customers

We may get your personal data directly from you, or in the event that you are part of a company, then company-specific personal data (like your name and company contact details) may be provided by your employer, or a designated contact.

How long we keep information

Our data processing policy is available from https://417-tech.com/legal/data-processing, which includes information on data retention.

Complaints

You may use the standard contact details from above to discuss this policy. In order to keep this document generic, our Data Protection Officer is not named, however they can be also be contacted directly with the following details:

Email: dpo (at) 417-tech (dot) com

Our ICO registration number is ZC200887.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://ico.org.uk/make-a-complaint