This notice was last updated on 10 March 2021.
The notice will be reviewed on an annual basis or when a change in legislation and/or practices dictates, and any changes will be notified to you by posting an updated version on our websites and/or by contacting you via email.
We recommend that you regularly check for changes and review this policy when visiting our websites.
The Commercial Services Group is committed to protecting your privacy. We take your privacy seriously and will only use the personal information that we collect from you or that you provide relating to the products and services you have requested from us or whereby you make an enquiry about our products or services.
If you have any concerns or questions relating to this notice, including how to update or access your personal information or to make a complaint, you will find our contact details in the Contact Us section below.
We are providing this privacy notice so you know who we are and what we do with any personal information we may collect.
This Privacy Notice explains
· Who the Commercial Services Group are
· What personal information we collect from you when you visit any of our websites, contact us or make an enquiry about any of our services or products
· How we collect, store and share personal information
· How we keep your personal information secure
· Your rights in relation to your personal information
· How you can make a Subject Access Request
· How you can make a complaint to the Information Commissioners Office (ICO)
By providing us with your information you consent to Commercial Services Group using your personal data as described in this notice.
2. WHO WE ARE
The Commercial Services Group trades under the following brand names and trading styles:
KCS Kent County Supplies
KCS Professional Services
CTS Vehicle Services
Our legal entities that we trade under are
Commercial Services Kent Limited
Commercial Services Trading Limited
Commercial Services Group is a trading style of both Commercial Services Trading Ltd (Reg No. 5858178) and Commercial Services Kent Ltd (Reg No. 5858177). Both companies are wholly owned by Kent County Council and registered in England and Wales.
Our head office address is:
Commercial Services Group
1 Abbey Wood Road
If you have any questions, suggestions or complaints about the processing of your personal information please contact our Data Protection Officer (DPO) via email at DPO@csltd.org.uk or in writing by using the address below:
Data Protection Officer
Commercial Services Group
1 Abbey Wood Road
3. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information in the following ways:
When you contact us by telephone, email, post or fax and also when you visit our websites.
The type(s) of information collected is likely to include your name, your job title, the company/business you work for and your contact details which could include your telephone number, email address and postal address along with details of your enquiry, quote or order.
When you visit our websites or social media pages your personal information may be automatically collected by our web servers and/or cookies. This information could include your IP address, the date and the pages that you visit.
Calls may be recorded for training purposes, quality control and for the purpose of capturing details about your enquiry including quotes, orders or sales contracts.
For more details about cookies and how we use them, please read our Cookie Notice.
We may also from time to time collect personal information from other sources outside of the Commercial Services Group. These could include other third-party companies and/or other local authorities, other government departments and information that is publicly available. The type of information we may collect is outlined above.
4. WHAT PERSONAL INFORMATION ARE WE COLLECTING
In order for the Commercial Services Group to provide its products and services it may be necessary for us to collect, maintain and process personal information about you, or the company/business which you work for.
Personal information we may collect includes the following;
· Your full name and contact information (including but not limited to, telephone number, email address, postal address, delivery address, job title and type of business/company)
· Bank account details
· Payment card details
· User names and account passwords (may be required when registering and/or login onto our websites)
· The details of your enquiry and/or quote, or any correspondence or complaint
· The date you contacted us
· Details of the goods or services you order
· Your marketing preferences
· Your delivery preferences
· Your social media user name
· Proof of delivery information (date, time and name of recipient)
· Credit rating details
· Vehicle number plate
· DVLA information
· Responses to feedback requests on our products and services
In addition to the above our recruitment division (trading names are Connect2Kent and Connect2Staff) may collect the following personal information in relation to candidates and their CV’s:
· Age and date of birth
· Marital status
· Employment history
· Education and qualification details
· Reference details
· Passport / driving licence or ID card
· Right to work
· National Insurance number
· DBS check
· Current salary and work related benefit schemes
· Criminal conviction check
5. WHY WE ARE COLLECTING THIS INFORMATION
We collect your personal information in order to:
· Manage your enquiry or quote
· Manage your account
· Deliver products or services
· Provide products and services to you as ordered
· Assist us in developing and improving our products and services
· Provide you with information and changes to our products or services
· Provide you with an employment/job opportunity through our recruitment division
6. OUR LEGAL BASES TO PROCESSING YOUR PERSONAL INFORMATION
There are a number of different legal bases that we may use in order to collect and/or process your personal information. These are listed below:
We will collect and process your personal information with your consent. Examples of this are when you tick a box to receive information on our products and services or to receive a newsletter or quote. When we give you the option to tick a box we will always make it clear what it is that you are consenting to.
You may withdraw your consent at any time by contacting us (see Contact Us section) or by using the unsubscribe links in our direct marketing emails.
When we have a contract with you, we will collect and process your personal information in order to fulfil our contractual obligation with you. An example of this is when we are delivering products or services that you have ordered, we will use your contact, address and specific instruction details to deliver them, which may include sharing your details with our delivery provider in order to fulfil and complete your orders.
We will use your personal information to comply with our legal obligations. This may mean that we need to provide your personal information to HMRC, DVLA and any other public authority. If requested, we will provide the police with personal information to assist them with investigations.
We may use your personal information should we need to contact you about an urgent safety issue with any of our products or services. This will be done with the intention of reducing or preventing harm.
We may use and process your personal information where we wish to pursue our legitimate interest as a business and in a way that you might reasonably expect us to do so. These interests are:
· To communicate and correspond with you
· To manage your enquiries, quotes or to respond to a complaint
· To comply with a request or a quote that you have made
· To understand your needs as a customer and to personalise our marketing to you
· To undertake credit checks
· To send you marketing information about similar goods, products and services you have previously purchased from us (unless you object)
· To send you marketing information about promotions on our product groups and services that you have previously purchased (unless you object)
· To conduct market analysis and research in order to improve and develop our products and/or services (this may include contacting you with customer surveys)
· To assist us in planning for marketing strategies
· To assist us in the technical administration of our websites (please see our Cookie Notice for further information)
7. RIGHTS OF ACCESS TO YOUR PERSONAL INFORMATION
Under current data protection law, you as an individual, have a number of rights in relation to the personal information we hold on you.
We may ask you to verify your identity or request more information about you in order for us to fulfil your request.
7.1 Your Right to Correcting and Updating your Personal Information
If any of the information we hold about you, or the business you work for changes, is inaccurate or out of date please contact one of the following divisions or services listed below that holds your information to make the changes.
|LASER Energy||Our public sector energy email@example.com|
|Lumina Energy||Our energy division providing energy brokerage firstname.lastname@example.org|
If you are unable to identify which of our divisions or services holds your personal information, please contact DPO@csltd.org.uk and we will direct your enquiry to the relevant team.
7.2 Your Right to Erase your Personal Information
You may ask for your personal information to be erased from our systems by emailing us at the following email address DPO@csltd.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.
We will comply with your request unless there is a lawful reason for us to continue to use and process your personal information.
7.3 Your Right to Restrict Processing of your Personal Information
You have the right to restrict the processing of your personal information in the following circumstances
Where you contest the accuracy of the personal information we hold on you
Where you believe your personal information has been unlawfully processed
Where you believe we no longer require your personal information for processing purposes or you require us to retain the information in order to establish, exercise or defend a legal claim
7.4 Your Rights to the Portability of your Personal Information
Your right to data portability allows you to obtain and re-use the personal information we hold on you for your own purposes. This will be provided to you in a structured, commonly used and machine-readable format (e.g., a CSV file). Machine-readable means that software can extract the data for other organisations to use. You can ask us to transfer your personal information directly to another service provider where technically feasible.
7.5 Your Right to Object to the Processing of your Personal Information
You have a right to object about how we process your personal information on the following grounds:
· Processing based on legitimate interest
· Processing based on performing a task in the public interest including profiling
· Direct marketing
You can exercise your right to object by emailing or writing to us at the following email address DPO@csltd.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.
You can also withdraw your consent and opt out from direct marketing by using the unsubscribe link at the bottom of our marketing emails.
Suppression lists will be maintained to screen against direct marketing information being sent to people who have already exercised their right to object to direct marketing. These lists will be held for compliance purposes only, and this does not affect your rights to be erased.
7.6 Your Rights Relating to Automated Decision Making (including profiling)
You have a right to understand and object to any automated decision making and/or profiling that is being carried out on your personal information.
You will need to make your request in writing to us and send your request to DPO@csltd.org.uk.
If you are a Connect2Staff or Connect2Kent candidate, you should read our Recruitment Candidate Privacy Notice.
8. RIGHT TO LODGE A COMPLAINT
You have a right to make a complaint with the supervisory authority if you have any concerns about the collection or processing of your personal information. The supervisory authority is the Information Commissioners Office (ICO) whose contact details can be found on their website https://ico.org.uk/.
9. HOW WE PROTECT YOUR PERSONAL INFORMATION
We take the protection of your personal information seriously and will treat it with care and take appropriate steps to protect it.
What we do to protect your personal information:
· Our systems, services, software and equipment meet acceptable security standards (such as Cyber Essentials)
· Our scanning security software is regularly checked to ensure it is functioning correctly
· Our computers are password protected and passwords are changed regularly
· Our systems are monitored for attacks
· We store printed documents that contain personal information securely and ensure that they are only accessed by authorised personnel
· We securely dispose of any personal information that is no longer required
· We verify the identity of anyone requesting access to personal information prior to providing it
10. DATA STORED OR HANDLED OUTSIDE OF THEK
Some of the personal information you provide to us may be transferred to countries outside the UK. Any third-party supplier holding data has the appropriate safeguards in place as to how that data is used and managed.
11. WHAT SPECIAL CATEGORIES OF PERSONAL DATA ARE COLLECTED
To provide certain services it may be necessary for us to collect personal information which is more sensitive. The special categories of personal information we collect or process may include information about your;
· Ethnic origin
· Trade union membership
· Sexual orientation
The circumstances in which we handle this personal information is likely to be on the behalf of other organisations and we will be acting as a processor
If you are a Connect2Staff or Connect2Kent candidate, you should read our Recruitment Candidate Privacy Notice.
12. WE SHARE YOUR PERSONAL INFORMATION
Your personal information may be shared with other divisions of the Commercial Services Group where there is a good reason to do so, for example to tell you about a product or service we reasonably expect you to be interested in. For a full list of our divisions see section headed ‘Who We Are.’
Sometimes it will be necessary for us to share your personal information with trusted third parties.
An example of this is when we use a logistics partner to deliver products to you.
We will only provide the information that this trusted third party needs to perform the expected task.
Trusted third parties that are under contract with us have agreed to only use the personal information provided to them for the purpose specified within the contract. All trusted third parties that we work with will be expected to act within current data protection regulations.
We work closely with our third-party suppliers to ensure that your personal information is respected and protected.
13. THE PROFILING WE DO
On some occasions we may collect or process your personal information using automated decision-making systems (a decision made by automated means and without any human intervention). We do this because we want to provide you with information, products and services that are of interest and are most relevant to you.
14. OUR RETENTION POLICY
We do not retain your personal information for longer than is necessary.
The length of time we retain your personal information for will be determined by the type of information we collect and the purpose that it has been processed for and/or our obligations under other laws.
· personal information processed under contractual obligations will be retained for 6 years beyond the last action on the contract
· when you place an order for products or services your personal information will be retained for 6 years (plus the current financial year) to fulfil our obligations under UK tax law
· where we receive your personal information in relation to an enquiry, quote or a complaint will be only hold this information for a reasonable time
· within our recruitment division (Connect2Kent, Connect2Staff, your personal information (eg CV) will be retained for up to 1 year after your last contact with us.
· we will hold your personal information for marketing purposes unless you have opted out or unsubscribed from receiving marketing information
If you are a Connect2Staff, Connect2Kent candidate you should read our Recruitment Candidate Privacy Notice.
If you have any concerns about our retention period, please contact the DPO@csltd.org.uk.
15. LINKS TO OTHER WEBSITES
Our Privacy Notice only applies to Commercial Services Group website and its divisions (for a full list of divisions see Who We Are).
Our websites may contain links to other organisations’ websites, which we do not control. These websites are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies.