Privacy Policy
Privacy Policy:
- Introduction
1 We are committed to safeguarding the privacy of [our website visitors and
service users].
1.2 This policy applies where we are acting as a data controller with respect to
the personal data of [our website visitors and service users]; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of [our website and services], we will ask you to consent to
our use of cookies when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can [specify whether you would
like to receive direct marketing communications and limit the publication of your
information]. You can access the privacy controls via [URL].
1.5 In this policy, “we”, “us” and “our” refer to [data controller name].[ For more
information about us, see Section 13.] - Credit
1 This document was created using a template from SEQ Legal
(https://seqlegal.com/free-legal-documents/privacy-policy).
You must retain the above credit. Use of this document without the credit is an infringement
of copyright. However, you can purchase from us an equivalent document that does not
include the credit. - How we use your personal data
1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you,
the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process [data about your use of our website and services] (“usage
data”). The usage data may include [your IP address, geographical location, browser
type and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and
pattern of your service use]. The source of the usage data is [our analytics tracking
system]. This usage data may be processed [for the purposes of analysing the use of
the website and services]. The legal basis for this processing is [consent] OR [our
legitimate interests, namely [monitoring and improving our website and services].
3.3 We may process [your website user account data] (“account data”).[ The
account data may [include your name and email address].][ The source of the account
data is [you or your employer].] The account data may be processed [for the purposes
of operating our website, providing our services, ensuring the security of our website
and services, maintaining back-ups of our databases and communicating with you.]
The legal basis for this processing is [consent] OR [our legitimate interests, namely
[the proper administration of our website and business]] OR [the performance of a
contract between you and us and/or taking steps, at your request, to enter into such a
contract]..
3.4 We may process [information that you post for publication on our website or
through our services] (“publication data”). The publication data may be processed
[for the purposes of enabling such publication and administering our website and
services]. The legal basis for this processing is [consent] OR [our legitimate interests,
namely [the proper administration of our website and business]] OR [the performance
of a contract between you and us and/or taking steps, at your request, to enter into
such a contract].
3.5 We may process [information contained in any enquiry you submit to us
regarding goods and/or services] (“enquiry data”). The enquiry data may be
processed [for the purposes of offering, marketing and selling relevant goods and/or
services to you]. The legal basis for this processing is [consent] OR [our legitimate
interests, namely [the proper administration of our website and business]] OR [the
performance of a contract between you and us and/or the taking steps, at your
request, to enter into such a contract].
3.6 We may process [information relating to transactions, including purchases of
goods and/or services, that you enter into with us and/or through our website]
(“transaction data”).[ The transaction data may include [your contact details, your
card details and the transaction details].][ The source of the transaction data is [you
and/or our payment services provider].] The transaction data may be processed [for
the purpose of supplying the purchased goods and/or services and keeping proper
records of those transactions]. The legal basis for this processing is [the performance
of a contract between you and us and/or taking steps, at your request, to enter into
such a contract; providing that, if you are not the person contracting with us, the legal
basis for this processing is our legitimate interests, namely [the proper administration
of our website and business].
3.7 We may process [information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters] (“notification data”). The
notification data may be processed [for the purposes of sending you the relevant
notifications and/or newsletters]. The legal basis for this processing is [consent] OR
[our legitimate interests, namely [communications with our website visitors and service
users]] OR [the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract].
3.8 We may process [basic customer information].[ This data may include [name
and contact details].][ The source of this data is [given willingly].] This data may be
processed for [specify purposes]. The legal basis for this processing is [consent] OR
[our legitimate interests, namely the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.9 We may process [any of your personal data identified in this policy] where
necessary for [the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure]. The legal basis for this
processing is our legitimate interests, namely [the protection and assertion of our legal
rights, your legal rights and the legal rights of others].
3.10 We may process [any of your personal data identified in this policy] where
necessary for [the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice]. The legal basis for this processing is our
legitimate interests, namely [the proper protection of our business against risks].
3.11 In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process [any of your personal data] where
such processing is necessary[ for compliance with a legal obligation to which we are
subject, or] in order to protect your vital interests or the vital interests of another
natural person.
3.12 Please do not supply any other person’s personal data to us, unless we
prompt you to do so. - Providing your personal data to others
1 We may disclose [your personal data] to [our insurers and/or professional
advisers] insofar as reasonably necessary for the purposes of [obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court proceedings or in
an administrative or out-of-court procedure].
4.2 [Your personal data held in our website database] will be stored on the
servers of our hosting services providers.
4.3 We may disclose [minor personal data] to [our suppliers or subcontractors][
identified at [URL]] insofar as reasonably necessary for [addressing a client issue].
4.4 In addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person.[ We may also disclose
your personal data where such disclosure is necessary for the establishment, exercise
or defence of legal claims, whether in court proceedings or in an administrative or
out-of-court procedure.] - International transfers of your personal data
1 In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to [countries outside the European Economic
Area (EEA)].
5.2 The hosting facilities for our website are situated in [United Kingdom/United
States].[ The European Commission has made an “adequacy decision” with respect to
[the data protection laws of each of these countries].][ Transfers to [each of these
countries] will be protected by appropriate safeguards, namely [the use of standard
data protection clauses adopted or approved by the European Commission, a copy of
which you can obtain from [source]].
5.3 The European Commission has made an “adequacy decision” with respect to
[the data protection laws of each of these countries].][ Transfers to [each of these
countries] will be protected by appropriate safeguards, namely [the use of standard
data protection clauses adopted or approved by the European Commission, a copy of
which can be obtained from [source]] OR [[specify appropriate safeguards and means
to obtain a copy]].]
5.4 You acknowledge that [personal data that you submit for publication through
our website or services] may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others. - Retaining and deleting personal data
1 This Section 6 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) [usage data will be retained for a minimum period of 14 months
following the date of collection, and for a maximum period of [86 months]
following that date];
(b) [account data will be retained for a minimum period of [14 months]
following the date of closure of the relevant account, and for a maximum period
of [86 months] following that date];
(c) [publication data will be retained for a minimum period of 6 months]
following the date when the relevant publication ceases to be published on our
website or through our services, and for a maximum period of [5 years] following
that date];
(d) [enquiry data will be retained for a minimum period of [1 year]
following the date of the enquiry, and for a maximum period of [10 years]
following that date];
(e) [transaction data will be retained for a minimum period of [0 days]
following the date of the transaction, and for a maximum period of [0 hours]
following that date];
(f)[notification data will be retained for a minimum period of [1 year] following the
date that we are instructed to cease sending the notifications, and for a
maximum period of [5 years] following that date (providing that we will retain
notification data insofar as necessary to fulfil any request you make to actively
suppress notifications)]; and
(g) [[data category] will be retained for a minimum period of [6 months]
following [date], and for a maximum period of [5 years] following [date]].
6.4 Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests or the vital interests
of another natural person. - Your rights
1 In this Section 7, we have listed the rights that you have under data protection
law.
7.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal
data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask use to restrict the
processing of your personal data;
(e) the right to object to processing – you can object to the processing of
your personal data;
(f)the right to data portability – you can ask that we transfer your personal data
to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain
about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn
more about the rights of data subjects by visiting
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-dataprotection-regulation-gdpr/individual-rights/.
7.4 You may exercise any of your rights in relation to your personal data [by
written notice to us, using the contact details set out below]. - About cookies
1 A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The identifier is
then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set expiry date,
unless deleted by the user before the expiry date; a session cookie, on the other hand,
will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a
user, but personal data that we store about you may be linked to the information
stored in and obtained from cookies. - Cookies that we use
1 We use cookies for the following purposes:
(a) [authentication and status – we use cookies [to identify you when you
visit our website and as you navigate our website, and to determine if you are
logged into the website.
(b) [personalisation – we use cookies [to store information about your
preferences and to personalise the website for you][ (cookies used for this
purpose are not applicable
(c) [security – we use cookies [as an element of the security measures
used to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally][ (cookies used for
this purpose are not applicable
(d) [advertising – we use cookies [to help us to display advertisements that
will be relevant to you][ (cookies used for this purpose are not applicable
(e) [analysis – we use cookies [to help us to analyse the use and
performance of our website and services][ (cookies used for this purpose are not
applicable
(f)[cookie consent – we use cookies [to store your preferences in relation to the
use of cookies more generally][ (cookies used for this purpose are not
applicable. - Cookies used by our service providers
1 Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.
10.2 We use Google Analytics. Google Analytics gathers information about the use
of our website by means of cookies. The information gathered is used to create
reports about the use of our website. You can find out more about Google’s use of
information by visiting https://www.google.com/policies/privacy/partners/ and you can
review Google’s privacy policy at https://policies.google.com/privacy.[ The relevant - Managing cookies
1 Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting cookies
via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-prefer
ences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delet
e-manage-cookies (Internet Explorer);
(e)
https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-datasfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many
websites.
11.3 If you block cookies, you will not be able to use all the features on our
website. - Amendments
1 We may update this policy from time to time by publishing a new version on
our website.
12.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
12.3 We [may] OR [will] notify you of [changes] OR [significant changes] to this
policy [by email]. - Our details
1 This website is owned and operated by [Stuart Wedge & PC Support
Midlands].
13.2 We are registered in [England and Wales] under registration number
[03688095], and our registered office is at [Springhill Cl, Willenhall, WV12 5LW].
13.3 Our principal place of business is at [Springhill Cl, Willenhall, WV12 5LW].
13.4 You can contact us:
(a) [by post, to [the postal address given above]];
(b) [using our website contact form];
(c) [by telephone, on [the contact number published on our website]]; or
(d) [by email, using [the email address published on our website]]. - Data protection officer
1 Our data protection officer’s contact details are: [support@pcsm.co.uk].
Section 1.2
“Personal data” is defined in Article 4(1) of the GDPR:
“‘personal data’ means 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”.
Section 2: Credit
Section: Free documents licensing warning
Optional element. Although you need to retain the credit, you should remove the inline
copyright warning from this document before use.
Section 3: How we use your personal data
The GDPR requires that controllers disclose to data subjects detailed information about their
processing of personal data.
Article 13(1) of the GDPR provides that:
“Where personal data relating to a data subject are collected from the data subject, the
controller shall, at the time when personal data are obtained, provide the data subject with all
of the following information: … (c) the purposes of the processing for which the personal data
are intended as well as the legal basis for the processing; (d) where the processing is based
on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third
party”.
Article 14(1) of the GDPR provides that:
“Where personal data have not been obtained from the data subject, the controller shall
provide the data subject with the following information: … (c) the purposes of the processing
for which the personal data are intended as well as the legal basis for the processing; (d) the
categories of personal data concerned …”.
Article 14(2) of the GDPR, which also applies in the case that the personal data have not
been obtained from the data subject, provides that:
“In addition to the information referred to in paragraph 1, the controller shall provide the data
subject with the following information necessary to ensure fair and transparent processing in
respect of the data subject: … (b) where the processing is based on point (f) of Article 6(1),
the legitimate interests pursued by the controller or by a third party … (f) from which source
the personal data originate, and if applicable, whether it came from publicly accessible
sources … “.
Article 6(1)(f) of the GDPR, which is referred to in Articles 13 and 14, provides that:
“(1) Processing shall be lawful only if and to the extent that at least one of the following
applies: … (f) processing is necessary for the purposes of the legitimate interests pursued by
the controller or by a third party, except where such interests are overridden by the interests
or fundamental rights and freedoms of the data subject which require protection of personal
data, in particular where the data subject is a child.”
As regards the identification of the source of personal data in the case that the personal data
is not obtained from the data subject, the guidance from the European Data Protection
Board states that:
“The specific source of the data should be provided unless it is not possible to do so … . If
the specific source is not named then information provided should include: the nature of the
sources (i.e. publicly / privately held sources) and the types of organisation / industry /
sector.”
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=622227
Note that, while Article 14 of the GDPR provides that information about “the categories of
personal data concerned” must be supplied to data subjects, Article 13 does not include an
equivalent provision. Nonetheless, we have included references to general categories of
data in this document, because this facilitates the identification of particular purposes of
processing and the legal bases of processing – information which does need to be provided
under Article 13.
The UK Information Commissioner’s Office website provides useful guidance in relation to
the selection of the legal bases for processing:
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protect
ion-regulation-gdpr/lawful-basis-for-processing/
Section 4: Providing your personal data to others
Article 13(1)(e) of the GDPR requires that where personal data are collected from the data
subject, the data controller must provide the data subject with information about “the
recipients or categories of recipients of the personal data”.
Equivalent rules for data collected from someone other than the data subject are in Article
14(1)(e).
Although the GDPR refers to “categories of recipients”, the guidance from the European
Data Protection Board on this subject states:
“The term ‘recipient’ is defined in Article 4.9 as ‘a natural or legal person, public authority,
agency or another body, to which the personal data are disclosed, whether a third party or
not’ [emphasis added]. As such, a recipient does not have to be a third party. Therefore,
other data controllers, joint controllers and processors to whom data is transferred or
disclosed are covered by the term ‘recipient’ and information on such recipients should be
provided in addition to information on third party recipients. The actual (named) recipients of
the personal data, or the categories of recipients, must be provided. In accordance with the
principle of fairness, controllers must provide information on the recipients that is most
meaningful for data subjects. In practice, this will generally be the named recipients, so that
data subjects know exactly who has their personal data. If controllers opt to provide the
categories of recipients, the information should be as specific as possible by indicating the
type of recipient (i.e. by reference to the activities it carries out), the industry, sector and
sub-sector and the location of the recipients.”
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=622227
Section 5: International transfers of your personal data
Optional element.
Article 13(1)(f) of the GDPR requires that data controllers disclose to data subjects “where
applicable, the fact that the controller intends to transfer personal data to a third country or
international organisation and the existence or absence of an adequacy decision by the
Commission, or in the case of transfers referred to in Article 46 [transfers subject to
appropriate safeguards] or 47 [binding corporate rules], or the second subparagraph of
Article 49(1) [limited transfers for compelling legitimate interests], reference to the
appropriate or suitable safeguards and the means by which to obtain a copy of them or
where they have been made available”.
The European Data Protection Board guidance on this issue states:
“The relevant GDPR article permitting the transfer and the corresponding mechanism …
should be specified. Information on where and how the relevant document may be accessed
or obtained should also be provided e.g. by providing a link to the mechanism used. In
accordance with the principle of fairness, the information provided on transfers to third
countries should be as meaningful as possible to data subjects; this will generally mean that
the third countries be named.”
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=622227
Section 6: Retaining and deleting personal data
Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental rules of
the regime:
“Personal data shall be: … 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 … “.
Article 13(2) of the GDPR provides, in relation to personal data collected from the data
subject, that:
“… the controller shall, at the time when personal data are obtained, provide the data subject
with the following further information necessary to ensure fair and transparent processing:
(a) the period for which the personal data will be stored, or if that is not possible, the criteria
used to determine that period …”.
Article 14(2) of the GDPR makes similar provision in relation to personal data that is not
collected from the data subject.
The European Data Protection Board guidance on this issue states:
“This is linked to the data minimisation requirement in Article 5.1(c) and storage limitation
requirement in Article 5.1(e). The storage period (or criteria to determine it) may be dictated
by factors such as statutory requirements or industry guidelines but should be phrased in a
way that allows the data subject to assess, on the basis of his or her own situation, what the
retention period will be for specific data / purposes. It is not sufficient for the data controller
to generically state that personal data will be kept as long as necessary for the legitimate
purposes of the processing. Where relevant, the different storage periods should be
stipulated for different categories of personal data and/or different processing purposes,
including where appropriate, archiving periods.”
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=622227
Section 6.3
For guidance on setting retention periods, see:
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protect
ion-regulation-gdpr/principles/storage-limitation/
Section 7: Your rights
Article 13(2) of the GDPR provides that, where personal data is collected from a data
subject, certain information about data subject rights must be provided:
“In addition to the information referred to in paragraph 1, the controller shall, at the time
when personal data are obtained, provide the data subject with the following further
information necessary to ensure fair and transparent processing: … (b) the existence of the
right to request from the controller access to and rectification or erasure of personal data or
restriction of processing concerning the data subject or to object to processing as well as the
right to data portability; (c) where the processing is based on point (a) of Article 6(1) or point
(a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting
the lawfulness of processing based on consent before its withdrawal; …”.
Similar provisions are set out in Article 14 in relation to personal data which is not collected
from the relevant data subject.
The European Data Protection Board guidance on this issue states:
“This information should be specific to the processing scenario and include a summary of
what the right involves and how the data subject can take steps to exercise it and any
limitations on the right … . In particular, the right to object to processing must be explicitly
brought to the data subject’s attention at the latest at the time of first communication with the
data subject and must be presented clearly and separately from any other information.”
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=622227
Section 8: About cookies
Optional element.
Under EU law, there are two additional requirements in relation to the use of cookies and
similar technologies, which apply over-and-above the rules regulating the processing of
personal data: a consent requirement and an information disclosure requirement. The
provisions of this document relating to cookies are designed to aid compliance with the
information disclosure requirement.
This requirement derives from Article 5(3) of Directive 2002/58/EC of the European
Parliament and of the Council of 12 July 2002 concerning the processing of personal data
and the protection of privacy in the electronic communications sector (Directive on privacy
and electronic communications), which provides that:
“Member States shall ensure that the use of electronic communications networks to store
information or to gain access to information stored in the terminal equipment of a subscriber
or user is only allowed on condition that the subscriber or user concerned is provided with
clear and comprehensive information in accordance with Directive 95/46/EC, inter alia about
the purposes of the processing, and is offered the right to refuse such processing by the
data controller. This shall not prevent any technical storage or access for the sole purpose of
carrying out or facilitating the transmission of a communication over an electronic
communications network, or as strictly necessary in order to provide an information society
service explicitly requested by the subscriber or user.”
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32002L0058&from=EN
The requirement is implemented in the UK in the Privacy and Electronic Communications
(EC Directive) Regulations 2003. In its current (amended) form, Regulation 6 states:
“(1) Subject to paragraph (4), a person shall not store or gain access to information stored, in
the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are
met.
(2) The requirements are that the subscriber or user of that terminal equipment – (a) is
provided with clear and comprehensive information about the purposes of the storage of, or
access to, that information; and (b) has given his or her consent.
(3) Where an electronic communications network is used by the same person to store or
access information in the terminal equipment of a subscriber or user on more than one
occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph
(2) are met in respect of the initial use.
(3A) For the purposes of paragraph (2), consent may be signified by a subscriber who
amends or sets controls on the internet browser which the subscriber uses or by using
another application or programme to signify consent.
(4) Paragraph (1) shall not apply to the technical storage of, or access to, information – (a)
for the sole purpose of carrying out the transmission of a communication over an electronic
communications network; or (b) where such storage or access is strictly necessary for the
provision of an information society service requested by the subscriber or user.”
In their original form, these Regulations can be found at:
http://www.legislation.gov.uk/uksi/2003/2426/made
Section 8.2
Optional element.
Section 8.3
Optional element.
Section 9: Cookies that we use
Optional element.
Section 10: Cookies used by our service providers
At Present the website may authorise third-party cookies for www.wordpress.com. These
cookies are not individually monitored by PC Support Midlands.
Section 11: Amendments
Any amendments to this document will be arranged and carried out by PC Support Midlands
and notifications will be made via the website [www.pcsm.co.uk]
[www.supportmidlands.co.uk]
Section 12: Our details
UK companies must provide their corporate names, their registration numbers, their place of
registration and their registered office address on their websites (although not necessarily in
this document).
Sole traders and partnerships that carry on a business in the UK under a “business name”
(i.e. a name which is not the name of the trader/names of the partners or certain other
specified classes of name) must also make certain website disclosures: (a) in the case of a
sole trader, the individual’s name; (b) in the case of a partnership, the name of each member
of the partnership; and (c) in either case, in relation to each person named, an address in the
UK at which service of any document relating in any way to the business will be effective. All
websites covered by the Electronic Commerce (EC Directive) Regulations 2002 must
provide a geographic address (not a PO Box number) and an email address. All website
operators covered by the Provision of Services Regulations 2009 must also provide a
telephone number.
Section 13
The company website of www.pcsm.co.uk [www.supportmidlands.co.uk] is formatted by
PC Support Midlands Ltd and hosted by www.worpress.com.
Section 14: Data protection officer
The data protection officer can be contacted at sales@pcsm.co.uk. Any data protection
request put forward will be assigned and acknowledged within 14 days. The process must
then be carried for to completion within 14 days of the acknowledgement date.
Section 14.1
Some data controllers and data processors will have an obligation to appoint a data
protection officer (DPO). The basic obligation is set out in Article 37(1) of the GDPR:
“The controller and the processor shall designate a data protection officer in any case where:
(a) the processing is carried out by a public authority or body, except for courts acting in their
judicial capacity; (b) the core activities of the controller or the processor consist of processing
operations which, by virtue of their nature, their scope and/or their purposes, require regular
and systematic monitoring of data subjects on a large scale; or (c) the core activities of the
controller or the processor consist of processing on a large scale of special categories of
data pursuant to Article 9 and personal data relating to criminal convictions and offences
referred to in Article 10.”
Article 13(1) of the GDPR provides that:
“Where personal data relating to a data subject are collected from the data subject, the
controller shall, at the time when personal data are obtained, provide the data subject with all
of the following information … (b) the contact details of the data protection officer, where
applicable”.
See also Article 14(1)(b).
Privacy policy of PC Support Midlands ltd 2020.