Data Protection Policy
Intouch Relocations has updated its Data Protection Policy to be compliant with GDPR, which is designed to protect the personal data of citizens of the European Union. It is Intouch Relocations policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.
- Personal data: 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
- Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
- The legal basis for processing personal data is clear and unambiguous
- A Compliance officer has been appointed with specific responsibility for the GDPR implementation in the organisation and can be contacted at firstname.lastname@example.org
- All staff involved in handling personal data understand their responsibilities for following good data protection practice
- Training in data protection has been provided to all staff
- Rules regarding consent are followed
- Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
- Regular reviews of procedures involving personal data are carried out
- Privacy by design is adopted for all new or changed systems and processes
- These actions are reviewed on a regular basis as part of the management process concerned with data protection.
2. Principles Relating to Processing of Personal Data
2.1. Personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
- 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, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’)
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
- 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 (‘accuracy’)
- 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 in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’)
- 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 (‘integrity and confidentiality’).
It is Intouch Relocations policy to comply with these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
3. Rights of the Individual
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Each of these rights are supported by appropriate procedures within Intouch Relocations that allow the required action to be taken within the timescales stated in the GDPR.
4. Lawfulness of Processing
There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is Intouch Relocations policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation.
- Consent: Unless it is necessary or otherwise permitted for a reason allowable in the GDPR, Intouch Relocations will obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge. If the personal data are not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.
- Performance of a Contract: Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to
- Legal Obligation: If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.
- Vital Interests of the Data Subject: If the personal data is required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing.
- Task Carried Out in the Public Interest: Where Intouch Relocations needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested.
- Legitimate Interests: If the processing of specific personal data is in the legitimate interests of Intouch Relocations and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing.
5. Privacy by Design Intouch Relocations has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect, or process personal data will be subject to due consideration of privacy issues.
6. Contracts Involving the Processing of Personal Data: Intouch Relocations will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
7. Breach Notification: It is Intouch Relocations to, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours.
8. Addressing Compliance to the GDPR: The following actions are undertaken to ensure that Intouch Relocations complies at all times with the accountability principle of the GDPR:
What information do we collect?
We collect information from you when you register on our site or fill out a form, as well as via other means such as email and telephonic in the performance of our services.
When registering on our site, as appropriate, you may be asked to enter your: Name, e-mail address, mailing address or phone number.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
To deliver services as authorised
To personalise your experience
(your information helps us to better respond to your individual needs);
To improve our website
(we continually strive to improve our website offerings based on the information and feedback we receive from you);
To improve customer service
(your information helps us to more effectively respond to your customer service requests and support needs);
To send periodic emails.
The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Database to be only accessed by those authorised with special access rights to our systems, and are required to? Keep the information confidential.
After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.
Yes (Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still place orders over the telephone or by contacting customer service.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
Terms and Conditions
This policy was last modified on 02 August 2016.