Data Protection Policy
Data Protection Policy
Approved by: Tim Ogden, Managing Director
Approval date: 21 April 2024
Last updated: July 8 2024
Next review date: 25 April 2025
This Data Protection Policy describes Mercury Strategic Services’ policies and procedures on the collection, use, and disclosure of Client and partner information as well as the legal obligations and restrictions pertinent to the use of this data.
Definitions
Organisation means Mercury Strategic Services, a company registered under number 405701478.
DPA means the Data Protection Act 2018 which implements the EU’s General Data Protection Regulation.
Client means any subscriber or purchaser of Mercury Strategic Services’ suite of services, including purchasers of partner or affiliate products and equipment.
Responsible Person means any member of the Organisation that is authorized to respond to data related matters.
Register of Systems means a register of all systems or contexts in which personal data is processed by the Organisation.
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1. Data Protection Principles
a. The Organisation is committed to processing data in accordance with its responsibilities under the DPA. DPA requires that personal data shall be: i. processed lawfully, fairly and in a transparent manner in relation to individuals;
ii. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
iii. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
iv. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or
rectified without delay;
v. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are
processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the DPA in order to safeguard the rights and
freedoms of individuals; and
vi. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate
technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by the Organisation. b. The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Organisation shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Organisation shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the Organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The Organisation shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Organisation’s systems.
e. We may share Client personal information in the following situations: i. With Service Providers: We may share Client personal information with Service Providers to monitor and analyze the use of our services, for
payment processing, to contact the Client.
ii. For business transfers: We may share or transfer Client personal information in connection with, or during negotiations of, any merger, sale of Organisation assets, financing, or acquisition of all or a portion of Our business to another company.
iii. With Affiliates: We may share Client information with our affiliates and partners, in which case we will require those affiliates to honor this
Privacy Policy. Affiliates include any parent company and any other
subsidiaries, joint partners or other companies that the organisation
controls or that are under common control with the organization.
iv. With business partners: We may share Client information with business partners to offer the Client certain products or services.
v. With Client consent: We may only disclose Client personal information for any other purpose with Client consent.
5. Data minimisation
a. a. The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. The Organisation may use this data for the purposes of;
i. To manage a Client's Account: to manage the Client registration for services. The Personal Data Clients provide can give the Client access to different functionalities of the Service that are available to the Client.
ii. For the performance of a contract: the development, compliance and undertaking of the contract for the products or services the Client has purchased or of any other contracts with the Organisation.
iii. To contact Clients: To contact Clients by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
iv. To provide Clients with relevant news, special offers, and general information about other partners we work with, additional services and events that are similar to those that the Client have already purchased or enquired about unless the Client has opted not to receive such
information.
v. To manage Client requests: To attend and manage Client requests to the Organisation.
vi. For business transfers: We may use Client information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Organisation’s assets,
whether as a going concern or as part of bankruptcy, liquidation, or
similar proceeding, in which Personal Data held by the organisation about our Clients is among the assets transferred.
6. Accuracy
a. The Organisation shall take reasonable steps to ensure personal data is accurate. b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Organisation shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
c. Should a Client decide to terminate its relationship with the organisation, the organisation will destroy all personal data and relevant information within the scope of this policy within 90 days of the Client’s decision.
8. Security
a. . The Organisation shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
a. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).