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PRIVACY NOTICE (TIER 4)

Document Control Reference: GDPR REC 4.1 Issue No: 1 Issue Date: 25th April 2018

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Efficient Print Management Limited collecting/processing their personal data.

2.2 All Employees/Staff of Efficient Print Management Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

Efficient Print Management Limited

Our GDPR Owner can be contacted directly here: terry@eqpm.co.uk • 0208 698 8250

The categories of data we process

• Personally identifiable data and details including names, address, telephone numbers.

The personal data we collect will be used:

• Fulfilling the printing requirements of our clients

Our legal basis for processing for the personal data:

• We will only collect and use your information where we have lawful grounds and legitimate business reasons to do so.

3.2 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Efficient Print Management Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by submitting a request to do so in writing direct to the company or via the website in line with our Withdrawal of Consent Procedure GDPR DOC 2.7A.

3.3 Disclosure

Efficient Print Management Limited will not pass on your personal data to third parties without first obtaining your consent. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

Third Party EU based organisation

Efficient Print Management Limited & geographic location

Third Parties UK based Printing Partners

Third country (non-EU)/international organisation

Efficient Print Management Limited do not send data to any Third Country (non EU based/International Organisations.

3.4 Retention period

Efficient Print Management Limited will process personal data for the duration of the contract and will store the personal data for as long as is necessary and in accordance with our customers’ requirements or as required by Law.

3.5 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.

• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

• Right of portability – you have the right to have the data we hold about you transferred to another organisation.

• Right to object – you have the right to object to certain types of processing such as direct marketing.

• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

• Right to judicial review: in the event that Efficient Print Management Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Efficient Print Management Limited (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Efficient Print Management Limited’s data protection representatives and GDPR Owner.

The details for each of these contacts are:

Supervisory authority contact details GDPR Owner contact details

Contact Name: Information Commissioners Office T Adshead, Managing Director

https://ico.org.uk/global/contact-us/

Address line 1: Unit 3 Bellingham Trading Estate,

Address line 2: Franthorne Way,

Address line 3: Bellingham, London

Address line 4: SE6 3BX

Email: terry@eqpm.co.uk

Telephone: 0208 698 8250

3.7 Privacy statement

Read more about how and why we use your data here - http://www.efficientprint.co.uk/privacy/4556229995

Document Owner and Approval

The GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff.

Signature: Date:

Change History Record

issue Description of Change Approval Date of Issue

1 Initial issue T Adshead 25th April 2018

4. Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

This privacy notice tells you how we, Efficient Print Management Limited, will collect and use your personal data for fulfilling the printing requirements of our clients.

Why does Efficient Print Management Limited need to collect and store personal data?

In order for us to provide you with Printing Services we need to collect personal data for fulfilling your printing requirements and for any correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Efficient Print Management Limited would contact you for additional consent.

Will Efficient Print Management Limited share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Efficient Print Management Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the printing services they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Efficient Print Management Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Efficient Print Management Limited use the personal data it collects about me?

Efficient Print Management Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Efficient Print Management Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Efficient Print Management Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

Efficient Print Management Limited, at your request, can confirm what information we hold about you and how it is processed. If Efficient Print Management Limited does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.

• Contact details of the GDPR Representative, where applicable.

• The purpose of the processing as well as the legal basis for processing.

• If the processing is based on the legitimate interests of Efficient Print Management Limited or a third party, information about those interests.

• The categories of personal data collected, stored and processed.

• Recipient(s) or categories of recipients that the data is/will be disclosed to.

• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. • How long the data will be stored.

• Details of your rights to correct, erase, restrict or object to such processing.

• Information about your right to withdraw consent at any time.

• How to lodge a complaint with the supervisory authority.

• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

• The source of personal data if it wasn’t collected directly from you.

• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Efficient Print Management Limited accepts the following forms of ID when information on your personal data is requested:

Current Passport, driving licence, birth certificate or utility bill (from last 3 months).

Contact details of the GDPR Owner:

Data Protection officer / GDPR