ICTS (UK) Limited
4th January 2018
ICTS understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Means an account required to access and/or use certain areas and features of Our Site
Means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below
Means this website, www.icts.co.uk
UK and EU Cookie Law
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015
Means ICTS, a limited company registered in England under ICTS (UK) Limited, whose registered address is ICTS (UK) Limited: Tavistock House, Tavistock Square, London, WC1H 9LG
Information About Us
Our Site, http://www.icts.co.uk/ is owned and operated by ICTS UK & Ireland
Our Data Protection Officer is Bilal Hussain who can be contacted at DPO@icts.co.uk
We are regulated by Information Commissioners Office (ICO)
Scope – What Does This Policy Cover?
What Data Do We Collect?
How Do We Use Your Data?
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
We use your data to provide the best possible services to you. This includes:
Providing and managing your log into secure areas;
Performance cookies to allow us to count number of visitors and how they move around the Our Site;
Experience cookies to remember choices you make;
Although as a business we do not use the following it is worth noting marketing cookies allow websites to tailor adverts relevant to you;
In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the services we can provide you without your consent for us to be able to use such data.
Although we do not use any of the information for any form of marketing we must advise you that if we were ever to change our approach we will get your consent before we progress. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
You have given consent to the processing of your personal data for one or more specific purposes;
Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
Processing is necessary for compliance with a legal obligation to which we are subject;
Processing is necessary to protect the vital interests of you or of another natural person;
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
How and Where Do We Store Your Data?
We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct regular reviews to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy which is available on request.
Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
Data security is of great importance to us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
Ensuring that any personal data is Pseudonymised
Encryption of all devices
No internal transfer of personal data via email
Significantly reduce any paperwork with sensitive information
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
Do We Share Your Data?
We may share your data with ICTS Europe with it being part of our group.
We may have contracts with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights and GDPR.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the company.
In certain circumstances ICTS may be legally required to share certain data held by us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
What Happens If Our Business (or part of it) Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance. You will be notified if any part of the business is to exchange hands in due course of the process.
How Can You Control Your Data?
When you submit information via Our Site, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
You may access Our Site without providing any data at all.
You may withdraw your consent for us to use your personal data as set out in section in 5 at any time by contacting us using the details set out in section 15, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible services to you.
How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by ICTS (where such data is held). Please contact us for more details at DPO@icts.co.uk, or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy.
Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1. Right to request access to, deletion of or correction of, your personal data held by Us;
13.2. Right to complain to a supervisory authority;
13.3. Right to be informed of what data processing is taking place;
13.4. Right to restrict processing;
13.5. Right to data portability;
13.6. Right to object to processing of your personal data;
13.7. Rights with respect to automated decision-making and profiling (see section 14 below).
Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
The decision is necessary for the entry into, or performance of, a contract between the You and Us;
The decision is authorised by law; or
You have given you explicit consent.
14.3.Where We use your personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and the likely consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
14.4.We currently DO NOT make any automated decisions. In the event we change this we will obtain consent from you.
14.5.We currently DO NOT profile your personal data for any purpose. In the event we change this we will obtain consent from you.