Equiniti Cyber Security Privacy Notice
24 May 2018
We understand how important your personal data is and are committed to protecting and respecting your privacy.
‘Personal Data’ means any information relating to or which identifies you. This can include items such as your name, address, phone number, identification numbers (such as an account number or your national insurance number), location data or online identifiers. Personal data can be held electronically or in certain paper records.
The General Data Protection Regulation (GDPR) regulates the processing of personal data. The GDPR seeks to protect your rights to your personal data by setting out, amongst other things, the conditions under which the processing of personal data is lawful, the rights of data subjects and the standards that organisations that handle personal data must adopt. This Privacy Notice is issued in compliance with GDPR and seeks to explain:
- Who we are,
- Products and services covered by this Privacy Notice
- How we collect your personal data,
- Why we collect your personal data,
- How long we hold the personal data for,
- The conditions under which we may share it with others,
- Overseas processing,
- How we keep your personal data secure,.
- Your personal data rights and how to exercise them, and
- Useful information.
1. Who we are
Equiniti Cyber Security is a trading name of Equiniti Data Limited (EQD) which is part of the Equiniti Group of Companies, and is authorised and regulated by the Financial Conduct Authority. Our main business is cyber security products and services. Our registered address is 42-50 Hersham Road, Walton-on-Thames, Surrey KT12 1RZ and our ICO registration number is: Z9452802.
EQD is a ‘Data Controller’. This means that we are responsible for deciding how and why we hold and use personal data about you.
In this Privacy Notice, ‘we’, ‘us’ and ‘our’ will always mean EQD, as Data Controller.
If you have any questions about our Privacy Notice, how we use your personal data or if you wish to exercise your rights, you may contact our Compliance Team by email at email@example.com or our Data Protection Officer, at Highdown House, Yeoman Way, Worthing, BN99 3HH, via email DPO@equiniti.com or by calling 0333 207 5962.
2. Products and services covered by this Privacy Notice
This notice explains how EQD processes Personal Data as part of our products and services for our organisational clients applies to all EQD cyber security products and services, all of which are B2B and are listed below. EQD also provides B2B data products and services. if you would like to view the privacy notice for our B2B data products and services please email us at firstname.lastname@example.org.
- EQ CSzero
- Real-time cyber threat prevention platform, combining business know-how with specialist cyber security systems to intercept and prevent phishing attacks
- Open source intelligence platform to monitor cyber threats
3. How we collect your personal data
Our organisational clients choose which Personal Data of their customers and other parties to send to us, such as names, mobile phone numbers, email addresses, mailing addresses and device identifiers.
In a similar way to how search engines work, we search (and store) parts of the internet and the dark web to check for security risks that might negatively impact our clients. As part of this, we may capture your Personal Data which is publicly available on the internet and dark web. We only do this as part of providing security services to our clients. We do not target or focus our efforts on collecting data relating to particular members of the public who have no links to our clients.
4. Why we collect your personal data
We collect and process Personal Data for the legitimate interests of us and our customers for:
- identity verification;
- detection, investigation, assessment, monitoring and prevention of fraud and other crime;
- mitigation of financial and business risk; and/or
- compliance with anti-money laundering (AML), counter-terrorism financing (CTF), anti-bribery and corruption (ABC) and similar laws.
5. How long we hold your personal data for
We retain Personal Data for only as long as necessary to provide the service and fulfil the transactions our clients have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.
Our practices and processes are designed to protect the data that we process from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access using appropriate administrative, physical and technical security measures.
For full details of our retention policies, please contact the Data Protection Officer using the above details.
6. The conditions under which we may share your personal data with others
We share information:
- with our clients and our processors;
- where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; detect, investigate and help prevent security, fraud or technical issues; and/or protect the rights, property or safety of EQD, our users, employees or others; and
- as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.
7. Overseas Processing
We process Personal Data where Equiniti Group affiliates and their service providers maintain servers and facilities, including the UK and Ireland. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.
8. How we keep your personal data secure
We take appropriate steps to ensure that Personal Data we process remains secure.
Once your personal data is received by us, we take its security very seriously. We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your personal data across all our computer systems, networks, websites, offices and stores as much as possible. In particular, our Information Security policy set is aligned to ISO 27001, which is an internationally recognised security standard.
We also use secure means to communicate with you where appropriate, such as ‘‘https’’ and other security and encryption protocols. This is indicated by a lock icon on the bottom of the web browser, or the address will include the letters https in the top left-hand corner.
9. Your personal data rights and how to exercise them
|Your rights in respect of the personal information that we hold about you
|The right to be informed about how we use your personal data.||This Privacy Notice provides you with the details on how we use and process your data.|
|The right of access to a copy of any personal data EQD processes about you, together with certain additional information.||If you request to see your personal data, your initial request will be free of charge; subsequent requests may attract an administration fee. The additional information includes details of the categories and recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.|
|The right to request us to rectify or update it.||This will be relevant where the personal data we hold is or has become inaccurate or incomplete, taking into account the purposes of the processing. Please explain why you consider the data inaccurate or incomplete.|
|The right to request us to erase your personal data in certain circumstances.
|The circumstances when erasure can apply include when we no longer need it to meet a lawful basis for processing unless that basis is consent and you withdraw your consent or you object to the processing or the processing is unlawful.
However, certain exclusions apply – where the processing is necessary for compliance with a legal obligation or to establish, exercise or defend legal claims.
|The right to request us to restrict processing it.||This request can be used to stop us processing your personal data if you disagree over the accuracy of the personal data, the reason for processing or if you wish us to retain your personal data for longer than our retention period, e.g. to establish, exercise or defend a legal claim.|
|The right to request a copy of your information for data portability purposes.||If you have provided personal data to us under contract or because you consented to the processing and use the data by automated means, then you have the right to instruct us to transmit that personal data to you or another data controller in a machine-readable format.|
|The right to object to us processing your personal data.||You have a right to object to us processing your data where we are processing it for the purpose of legitimate interests.
You can also object to direct marketing communications from us about products, offers, competitions, or services and any profiling that we may perform in relation to direct marketing. You can do this at the point of data collection, through the use of any opt-out functionality on text and emails, via your preference centre or by contacting your helpline service.
You can update your marketing preferences at any time through the use of the opt-out functionality.
You have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing before the withdrawal.
If you would like to receive the marketing described above, please ensure you have indicated your preferences accordingly.
|Rights related to decisions based solely on automated processing.||Where this processing produces legal effects or significantly affects you, you can object to this processing unless the processing is necessary as part of our contract, or is required by legislation.|
|Right to lodge a complaint with a supervisory authority.||If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection team who will investigate the matter and report back to you.
If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country. In the UK, it is the Information Commissioner’s Office (ICO) who regulates Data Controllers compliance with data protection legislation. They can be contacted by email: email@example.com, post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113.
10. Useful information
10.1 – Use of ‘cookies’
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity, and do not identify you as an individual. This helps us to improve our website and deliver a better more personalised service.
It is possible to switch off cookies by setting your browser preferences. However, turning cookies off may result in a loss of functionality when using our website. For more information on how to switch off cookies on your computer, visit our full Cookies Policy.
10.2 – Links to other websites
Our websites may contain links to other websites run by other organisations, or other Equiniti companies. This Privacy Notice applies only to EQD websites, where the link appears. When you are on another website, we encourage you to read their privacy statements as it will take precedence over this Policy.
We cannot be responsible for the privacy policies and practices of other sites.
10.3 – Social media, blogs, reviews, and similar services
Any social media posts or comments you make to us (e.g. on our own Facebook page) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they are made and could be made public by that platform. These platforms are controlled by other organisations, and so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information, what information relating to you they will place in the public domain and how you can stop them from doing so if you are unhappy about it.
Any blog, review or other posts or comments you make about us, our products and Services on any of our blog, review or user community services will be shared with all other members of that service and the public at large.
You are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
10.4 Changes to this policy
We review our use of personal data regularly. In doing so, we may change what personal data we collect, how we keep it and or what we do with it. As a result, we may change this Privacy Notice from time to time to keep it relevant and up to date.
This policy was issued on 24 May 2018.
If you require copies of previous versions of the EQ Cyber Security Privacy Notice, please contact the Data Protection Officer using the contact details noted above.
We review our use of your information regularly. In doing so, we may change what personal data we collect, how we keep it and or what we do with it. As a result we may change this Policy from time to time to keep it relevant and up to date.