1.WHO ARE WE
1b. We have a data protection lead who is responsible for all of our issues relating to the protection of personal data. The data protection lead can be contacted at the below:
The Data Protection Lead
MS3 Networks Limited
Priory Park West
2. WHO DOES THIS DOCUMENT APPLY TO
(2) Prospective customers;
(3) Individuals that use our websites;
(4) Former customers;
(5) Nominated users or individuals acting under a power of attorney;
(6) Shareholders; and
(7) Members of the public.
2b. Our services are not intended for children, unless we expressly state otherwise, and we do not knowingly collect or process personal data relating to children or anyone aged under 18 years.
2c. It is important that the personal data we hold about you is accurate and current. It’s your responsibility to keep us up to date if you make any changes to your personal data either through contacting MS3 by phone or by email.
3. WHAT INFORMATION DO WE HOLD?
3a. Personal data is any information that can identify a natural person. We may collect, use, store and transfer different categories of personal data to enable us to deliver our services, as follows:
(1) Data about your Identity including first name, last name, title, date of birth and gender;
(2) Data about your contact details including service address, correspondence/billing address, email address, landline telephone number and mobile phone number;
(3) Financial data including your bank account details for a direct debit and payment card details;
(4) Data relating to a transaction including details about payments to and from you and about the products and services that you have purchased from us;
(5) Technical data including IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, online chat logs and other information on the devices you use to access our services;
(6) Data about your usage of our products and services including the amount of time you spend online, websites you visit.
(7) Data relating to images/recordings captured by body worn video (Body cams).
3b. We may also collect and use non-personal data such as statistical or demographic data. This data may be derived from your personal data but is not considered personal data as this data cannot identify you.
4 HOW DO WE COLLECT INFORMATION?
4a. Information you give us
(1) When you place an order with us for any of our services (for example over the phone, online or through a third-party affiliate), we will need certain information to process your order.
(2) When you contact us to discuss your services, we may ask for certain information to be able to confirm your identity, check our records and answer your questions quickly and accurately.
(3) When body cams have been activated by the operator.
4b. Information we automatically collect
(1) We will automatically collect information:
• when you use our services; and
• when you visit our website, we may collect and process information about your us-age of these by using “cookies” and other similar technologies to help us make im-provements to the websites and to the services we make available.
4c. Information we receive from other sources
(1) We may receive personal data about you from third parties or publicly available sources in
the following categories:
• companies contracted by us to help us provide services to you;
• other telecommunications operators when transferring services;
• marketing organisations;
• credit reference agencies or fraud prevention agencies.
5. HOW DO WE USE THE INFORMATION HELD
5a. The information we collect helps us to better understand what you need from us and to improve
the provision of our services to you.
5b. We use the information collected for example to:
(1) verify your identity when you use our services or contact us;
(2) process your enquiries or orders;
(3) monitor, record, store and use any telephone, e-mail or other electronic communications with you for training purposes, so that we can check any instructions given to us and to improve the quality of our customer service, and in order to meet our legal and regulatory obligations;
(4) where you have agreed, provide you with information about other MS3 services, offers
or products which you may be interested in;
(5) to tell you about changes to our websites, services or terms and conditions;
(6) carry out any marketing analysis, profiling or create statistical or testing information to help us personalise the services we offer you and to understand what our customers want;
(7) recover any monies you may owe to us for using our services;
(8) analyse our services with the aim of improving them; and
(9) prevent or detect a crime, fraud or misuse of, or damage to our network, and to investigate where we believe any of these have occurred.
5c. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law.
5d. We may supplement the information directly collected by us with data from third parties (for example socio-demographic data) to further improve the services or products we offer customers.
6. WHEN MIGHT WE SHARE YOUR DATA WITH OTHER PARTIES
6a. We may need to share your information with organisations outside MS3 e.g. to help us provide our services to you.
6b. The categories of non-MS3 parties that we would share your details with are:
(1) Third party suppliers who help MS3 Networks to perform our services;
(2) Professional advisors;
(3) Legal representatives;
(4) Law enforcement agencies;
(5) Other companies as part of the process of selling one or more of our businesses or part of those businesses; and
(6) Regulators (such as Ofcom or the ICO).
6c. Where we share your information with third parties they are required to follow our express instructions in respect of the use of your personal information and they must comply with all applicable UK data protection laws to protect your information and keep it secure.
7. PROTECTING INFORMATION
7a. We take protecting your data seriously and will do our utmost to employ appropriate organisational and technical security measures to protect you against unauthorised disclosure or processing.
7b. Unfortunately, we cannot guarantee the security of transmitting information via the internet. We have tried to create a secure and reliable website for our users in line with industry standards. However, we have no responsibility or liability for the security of personal information transmitted via the internet.
8. WHY DO WE PROCESS YOUR DATA?
8a. We process each type of personal data for one the following reasons:
(1) We need to process the data under our contract with you for our services;
(2) We have a legitimate interest as a business in processing your data;
(3) We have a legal obligation to process the data;
(4) We have your consent (which you can withdraw at any time); or
(5) We have vital interests in some circumstances.
8b. If you don’t provide us with the data we need then we may not be able to perform our contract with you and may need to terminate the contract. If this happens we will notify you as set out in our Terms and Conditions.
9 HOW LONG DO WE HOLD YOUR INFORMATION?
9a. Unless there is a specific regulatory or legal requirement for us to keep your information longer, we will keep your information for as long as it is necessary for the purpose for which it was collected.
9b. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
10 YOUR RIGHTS
10a. As a data subject you have a number of personal rights under data protection laws in relation to your personal data. These are:
(1) Access - You have a right to access and receive personal data including any supplementary information.
(2) Erasure - In certain circumstances you have a right to request that your personal data be erased from the systems within our control.
(3) Rectification - You have a right to have inaccurate personal data rectified or completed if it is incomplete.
(4) Object – You have the right to object to processing of your personal data in certain circumstances.
(5) Restrict processing - You have a right to request the restricting or suppression of your personal data.
(6) Data portability – You have the right to obtain and reuse their personal data for their own purposes across different services.
10b. If you would like more information about these rights or how to apply them, please email directly to DPO@ms-3.co.uk, or use the ‘Contact Us’ section on our website.
11a. If you would like to make a complaint about our use of the personal data you should contact our Data Protection Lead at DPO@ms-3.co.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. If we have not resolved your complaint, you can contact the UK data protection regulator, the Information Commissioner’s Office (ICO) (www.ico.org.uk).