1. Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We will never sell, rent or otherwise distribute or make public your personal information
- Any person that has registered via this website is entitled to request access, amendment or removal of their registration data.
2. Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 2018 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Data Protection Act 2018
- The full terms of the Data Protection Act 2018 can be found at (http://www.legislation.gov.uk/ukpga/2018/12/contents/enacted)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our Data Protection Officer (details of which can be found in Section 7.0) for clarification.
3. Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
Like many websites, this site uses Google Analytics (GA) and Lead Forensics (LF) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA and LF record data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA and LF also records your computer’s IP address which could be used to personally identify you, but Google does not grant us access to this. We consider Google and Lead Forensics to be third-party data processors (see Section 5.0 below).
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies provided by external web traffic analysis services over which we have no control:
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it.
- This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Disabling cookies on your internet browser will stop GA and LF from tracking any part of your visit to pages within this website.
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact page, the data that you supply will be stored by this website. The data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP).
Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet.
The email content is then decrypted by our local computers and devices.
3.3 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be retained by 121 Systems and all email communications you receive will be sent from our own email system.
Your email address will never be passed to third parties.
While your email address remains within our 121 Systems database, you will receive periodic (approximately three times a year) newsletter-style emails from us.
4. How we store your personal information
As detailed in section 3.2 above, if you submit an enquiry or contact form some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website.
This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (WordPress).
5. Our third-party data processors
We use third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0.
Both these third parties are based in the USA and are EU-US Privacy Shield compliant.
6. Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
7. Data Controller
The data controller of this website is: 121 Systems, a UK Private Limited Company with company number: 04592619 (121 Systems Ltd)
Whose registered office and main office of operation is:
No1 Nottingham Science Park
Jesse Boot Avenue
Telephone: 0115 943 9130
8. Subject Data Access, Data Amendment or Removal Requests
In the event that you have successfully registered your details via this website you may at any time:
- Make a subject data access request
- Request amendment of your personal data
- Request to the removal of your personal data
Any such requests should be directed to 121 Systems’s Data Protection Officer, the contact details for which are detailed in Section 7 to this policy document.
We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the changelog below.
v1.0 07 December 2017 – initial document created
v1.1 22 March 2018 – revised document pending GDPR implementation
v1.2 28 March 2018 – DPO revisions
v1.3 1 November 2018 – Data Protection Act 2018