Complaints Procedure
We use a third party server to host our website, One to One. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Our third party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
This information is processed onto a front sheet and then forwarded to the awarding body to show due diligence by us that the person on the course is actually the person and not someone else. This information is only available to authorised personnel within Bolton Security Ltd or upon request from the awarding body or the SIA, (Security Industry Authority).These course details are then kept for a period of five years before being destroyed as per the guidance of the awarding body.
We do not at any time use your information for anything else except the odd marketing offers, and we do not at any time release or sell your information to any third parties.
No credit card details are stored at any time and are destroyed as soon as the transaction has been completed.
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is One to One.
When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect your company name if you provide it.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by Bolton Security Ltd
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Transfer and storage of your information
Information you send us by post is stored by Bolton Security Ltd.
When you place an order for goods or services on our website, we collect the following mandatory information: name, email address, phone number, billing address, company name (if applicable), VAT number (if applicable) and account password (if you create an account).
If you do not provide this information, we will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: other than phone number and password, we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing: compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation: other than phone number and password, we have a legal obligation to issue you with an invoice for the goods and services you purchased from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.
Legal basis for processing: we collect your phone number and password in our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s):
- we collect your password for our legitimate interests in: (i) registering and administering accounts on our website to provide you access to content and updates you have purchased; and (ii) to facilitate the efficient running and operation of our business.
- We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account
At checkout you will have the option of receiving marketing communications from us.
Offers relating to our goods and services
You can opt in to receiving marketing communications from us in relation to our goods and services by email by ticking the box ‘I would like to receive offers about products and services from GDPR Privacy Policy by email’.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, called MailChimp.
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use PayPal. Your payment will be processed by the payment provider you choose to process your payment via a payment gateway.
Legal basis for processing: necessary to perform a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Third party payment processors
The third party payment processors we use all collect, use and process your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via their own websites and policy links.
PayPal may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
As part of our ACS standard we regularly conduct personal and credit checks as part of our BS7858 vetting procedure. This involves collecting information about you from external agencies such as Equifax and the DBS service. This will only be conducted after receiving consent from the person involved.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1) (a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass your information on to us.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one). We may do this, for example, if we have insufficient information to be able to contact you or to better understand your business.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1) (b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.
Legal basis for processing: compliance with a legal obligation (Article 6(1) (c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to Google Inc.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partner’s page of Google’s privacy policy
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service and allowing the Google Analytics to work on our website
You can opt out of Google Analytics by installing the browser plugin here
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential
Legal basis for processing: legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers
Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1) (f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are Fabrons Accounting, 6th Floor, 120 Bark Street, Bolton, Lancs.
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and other specialists. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
All of our advisors are located in the United Kingdom.
Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in in any industry, sector or sub-sector. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.
All of our affiliates are located in the United Kingdom.
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
All our business partners are located in the United Kingdom.
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.
All our independent contractors are located in the United Kingdom.
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the United Kingdom.
Order information: when you place an order for goods and services, we retain that information for a minimum period of six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes under paragraph 6, Schedule 11 of the Value Added Tax Act 1994.
Correspondence and enquiries: when you make an enquiry or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.
Mailing list: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our newsletter service, whichever occurs first.
Course information will be kept and stored for a period of six years from the date of the beginning of the course or qualification.
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
- The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- Whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- Whether we have any legal basis to continue to process your information (such as your consent);
- How valuable your information is (both now and in the future);
- Any relevant agreed industry practices on how long information should be retained;
- The levels of risk, cost and liability involved with us continuing to hold the information;
- How hard it is to ensure that the information can be kept up to date and accurate; and
- Any relevant surrounding circumstances (such as the nature and status of our relationship with you).
All personal information is stored under strict conditions and in locked cabinets with only authorised personnel having access to them. They are stored for a period of six years as requested by the awarding bodies.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- Using secure servers to store your information;
- Verifying the identity of any individual who requests access to information prior to granting them access to information; and
- Using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- Using secure servers to store your information;
- Verifying the identity of any individual who requests access to information prior to granting them access to information; and
- Using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
All information no longer required is destroyed securely by Bolton Security Ltd and at no time during the process will any information be subject to third party access.
All information used by us will be done to ensure that we remain legal and ethical at all times and to meet any legal requirements, for example, fraud or money laundering. Information will also be used to meet internal and external audits such as the ACS (Approved Contractor Service) or to keep company records on approved suppliers.
Information may also be used for marketing purposes occasionally when Bolton Security have offers to promote.
Please note this list is not exhaustive.
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to: Philip Booth, Bolton Security Ltd, Unit 33 Bolton Technology Park, Spa Road, Bolton, Lancs. BL1 4AY. Or, sending an email to info@boltonsecurity.co.uk
- To request access to your information and information related to our use and processing of your information;
- To request the correction or deletion of your information;
- To request that we restrict our use of your information;
- To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- To object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information); and
- To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO). Contact details for the ICO are as follows: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Tel: 0303 123 1113.
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2) (a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
When taking part in a Physical Intervention programme we have to ask you to complete a pre-course medical questionnaire as well as an after course disclaimer. Any current injuries or medical conditions that may prevent you from completing the programme must be disclosed at the time. This information is kept private and confidential and stored securely at all times.
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.