What information does Microdesk collect from me?
Microdesk may collect customer information in a number of ways, but the two most common are during form submission, feedback submission, and product or service registration or download. In some instances, you may visit sections of our site and use some of our services without providing information to us. The information requested may vary depending on which product or service you are using or accessing. We typically ask for your basic contact information, such as your name, title, company name, e-mail address, postal addresses, telephone numbers and the industry that you work in. If you contact us, we may keep a record of that correspondence or communication. Information on how you communicated with us may also be recorded and can include your e-mail address including country domain, the language you selected for viewing order forms or other documents, your browser type, the currency in which you viewed prices if such feature is available, your use of a secure or insecure Web page, the return e-mail address shown in any e-mail message from you, the return address on any envelope or facsimile number on any facsimile, or the telephone number from which you called.
In addition to the information we obtain at the initial stage of form submission, we may ask you for information at other times, such as when you make a purchase or use a service on an Microdesk site; when you participate in a contest, survey, or promotion; when you submit a listing for a Web site; or when you report a problem with one of our sites or services. In most cases, the more specific information you provide, the better we are able to personalize your Web experience.
What are my choices regarding the use of my information?
When you register with Microdesk, you may choose whether you want to receive information from Microdesk or our partners about other products or services or about special promotions. If you do not want to receive this information, be sure to indicate that on your registration form if the form requires you to specify your choices. You also have choices about whether you want to receive this information when you visit and provide information to other sites, including sites accessible through an Microdesk site.
Where is my data stored?
What else should I know about my privacy?
Please keep in mind that whenever you voluntarily disclose personal information online – for example on message boards, through e-mail, or in chat areas – that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.
What We Collect
We may collect the following information:
- name and job title
- contact information including your email address
- demographic information such as postcode
- information relating to your preferences and interests
- website and product usage data
- other information collected through customer surveys
What we do with the collected information
We use this information to better understand your needs so we can provide improved products and services, and an enhanced customer experience. Specifically, we may use collected data for the following reasons:
- Internal record keeping to ensure any data we hold on you is accurate, up to date and secure.
- To improve our products and services.
- To contact you in response to an enquiry.
- To send you promotional emails about new products and services, special offers, and events we’re holding, or other information which we think might be relevant to you using the email address you have provided.
- To contact you via email, telephone or mail for market research purposes.
- To improve your experience of using our website and products.
We are committed to ensuring that your information is kept secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Controlling your Personal Information
You may choose to restrict the collection or use of your personal information in the following ways:
- Whenever you are asked to fill in a form on our website, do not tick the box that indicates you want to receive marketing emails from us.
- If you no longer wish us to use your personal information for email or direct marketing purposes, you may change your mind at any time by writing to or emailing us at firstname.lastname@example.org.
We will not disclose your personal information to third parties unless we are required by law to do so.
You may request details of personal information which we hold about you. If you would like a copy of the information held, please email at email@example.com
If you believe that any information we are holding in relation to you is incorrect or you wish to change how we communicate with you, please email us as soon as possible at firstname.lastname@example.org
Microdesk Ltd. Data Protection Policy
Microdesk Ltd. Data Protection Policy – to conform with the General Data Protection Regulation (‘GDPR’)
The purpose of the General Data Protection Regulation is to protect the “rights and freedoms” of individuals and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent. It applies to the processing of personal data both in electronic and in hard copy form.
Personal data is any information relating to an identifiable natural person who can be identified, directly or indirectly, by 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.
A Data controller is 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;
A Data subject is any living individual who is the subject of personal data held by an organisation.
Processing is any operation which is performed on personal data, 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.
A Personal data breach is a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Data subject consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.
A Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
The Board of Directors and management of Microdesk Limited (‘Microdesk Ltd.’) are committed to compliance with all relevant EU and Member State laws in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information Microdesk Ltd. collects and processes in accordance with the General Data Protection Regulation 2016 (GDPR).
This policy, alongside Microdesk Ltd.’s Information Security Policy and other related policies apply to Microdesk Ltd.’s personal data processing functions, including those performed on customers’, clients’, employees’, suppliers’ and partners’ personal data, and any other personal data the organisation processes from any source.
The Data Protection Officer is responsible for reviewing the Data Retention Schedules annually in the light of any changes to Microdesk Ltd.’s activities and to any additional requirements identified by means of any data protection impact assessments.
This policy applies to all staff of Microdesk Ltd. including any interested parties such as outsourced suppliers. Any breach of the GDPR will be dealt with under Microdesk Ltd.’s disciplinary policy and may also be a criminal offence, in which case the matter will be reported as soon as possible to the appropriate authorities. Partners and any third parties working with or for Microdesk Ltd., and who have or may have access to personal data, will be expected to have read, understood and to comply with this policy. No third party may access personal data held by Microdesk Ltd. without having first agreed to this policy and to Microdesk Ltd.’s GDPR contract addendum which imposes on the third party obligations no less onerous than those to which Microdesk Ltd. is committed, and which gives Microdesk Ltd. the right to audit compliance with such obligations.
Responsibilities and roles under the General Data Protection Regulation
Microdesk Ltd. is a data controller and a data processor under the GDPR.
Top Management and all those in managerial or supervisory roles throughout Microdesk Ltd. are responsible for developing and encouraging good information handling practices within Microdesk Ltd.; responsibilities are set out in individual job descriptions.
The Data Protection Officer is accountable to the Board of Directors of Microdesk Ltd. for the management of personal data within Microdesk Ltd. and for ensuring that compliance with data protection legislation and good practice can be demonstrated. This accountability includes:
development and implementation of the GDPR as required by this policy; and
security and risk management in relation to compliance with the policy.
The Data Protection Officer (DPO), who the Board of Directors considers to be suitably qualified and experienced, has been appointed to take responsibility for Microdesk Ltd.’s compliance with this policy on a day-to-day basis and, in particular, has direct responsibility for ensuring that Microdesk Ltd. complies with the GDPR, as do Managers in respect of data processing that takes place within their area of responsibility.
The DPO is the first point of call for those seeking clarification on any aspect of data protection compliance.
Compliance with data protection legislation is the responsibility of all staff of Microdesk Ltd. who process personal data.
Staff of Microdesk Ltd. are responsible for ensuring that any personal data about them and supplied by them to Microdesk Ltd. is accurate and up-to-date.
Data protection principles
All processing of personal data must be conducted in accordance with the data protection principles as set out in Article 5 of the GDPR. Microdesk Ltd.’s policies and procedures are designed to ensure compliance with the principles.
Personal data must be processed lawfully, fairly and transparently Lawful – identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example consent. Fairly – in order for processing to be fair, the data controller has to make certain information available to the data subjects as practicable. This applies whether the personal data was obtained directly from the data subjects or from other sources. The GDPR has increased requirements about what information should be available to data subjects, which is covered in the ‘Transparency’ requirement. Transparently – the GDPR includes rules on giving privacy information to data subjects in Articles 12, 13 and 14. These are detailed and specific, placing an emphasis on making privacy notices understandable and accessible. Information must be communicated to the data subject in an intelligible form using clear and plain language. Microdesk Ltd.’s Privacy Notice can be found here.
Personal data can only be collected for specific, explicit and legitimate purposes Data obtained for specified purposes must not be used for a purpose that differs from those agreed with the data subject.
Personal data must be adequate, relevant and limited to what is necessary for processing
The DPO is responsible for ensuring that Microdesk Ltd. does not collect information that is not strictly necessary for the purpose for which it is obtained.
Personal data must be accurate and kept up to date with every effort to erase or rectify without delay
Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate.
The DPO is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.
It is also the responsibility of the data subject to ensure that data held by Microdesk Ltd. is accurate and up to date.
Staff should be required to notify Microdesk Ltd. of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of Microdesk Ltd. to ensure that any notification regarding change of circumstances is recorded and acted upon.
The DPO is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors.
On at least an annual basis, the DPO will review the retention dates of all the personal data processed by Microdesk Ltd., by reference to the data retention schedules, and will identify any data that is no longer required in the context of the registered purpose. This data should be securely deleted/destroyed.
The DPO is responsible for responding to requests for rectification from data subjects within a reasonable timescale.
Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing.
Personal data will be retained in line with the Data Retention Schedules and, once its retention date is passed, it must be securely destroyed as set out in the schedule.
The DPO must specifically approve any data retention that exceeds the retention periods defined in the Data Retention Schedules, and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written.
Personal data must be processed in a manner that ensures the appropriate security The Data Protection Officer will carry out a risk assessment taking into account all the circumstances of Microdesk Ltd.’s controlling or processing operations. Microdesk Ltd. compliance with this principle is contained within Microdesk Ltd.’s Information Security Policy.
The controller must be able to demonstrate compliance with the GDPR’s other principles (accountability) The GDPR includes provisions that promote accountability and governance. These complement the GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility. Microdesk Ltd. will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, and implementing technical and organisational measures.
Data subjects’ rights
Data subjects have the following rights regarding data processing, and the data that is recorded about them:
To make subject access requests regarding the nature of information held and to whom it has been disclosed.
To prevent processing likely to cause damage or distress.
To prevent processing for purposes of direct marketing.
To be informed about the mechanics of automated decision-taking process that will significantly affect them.
To not have significant decisions that will affect them taken solely by automated process.
To sue for compensation if they suffer damage by any contravention of the GDPR.
To take action to rectify, block, erased, including the right to be forgotten, or destroy inaccurate data.
To request the supervisory authority to assess whether any provision of the GDPR has been contravened.
To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.
To object to any automated profiling that is occurring without consent.
Microdesk Ltd. ensures that data subjects may exercise these rights:
Data subjects may make data access requests.
Data subjects have the right to complain to Microdesk Ltd. relating to the processing of their personal data, the handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Microdesk Ltd. Complaints Procedure.
Microdesk Ltd. understands ‘consent’ to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time.
Microdesk Ltd. understands ‘consent’ to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them.
There must be some active communication between the parties to demonstrate active consent. Consent cannot be inferred from non-response to a communication.
For sensitive data, explicit written consent of data subjects must be obtained unless an alternative legitimate basis for processing exists.
Security of data
Microdesk Ltd.’s IT Security Policy governs how Microdesk Ltd. protects personal data.
Disclosure of data
Microdesk Ltd. must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for, the conduct of Microdesk Ltd.’s business.
All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures must be specifically authorised by the DPO.
Retention and disposal of data
Microdesk Ltd. shall not keep personal data in a form that permits identification of data subjects for longer a period than is necessary, in relation to the purpose(s) for which the data was originally collected.
The retention period for each category of personal data will be set out in the Microdesk Ltd. Retention Schedules along with the criteria used to determine this period including any statutory obligations Microdesk Ltd. has to retain the data. Personal data must be disposed of securely in accordance with the sixth principle of the GDPR – processed in an appropriate manner to maintain security, thereby protecting the “rights and freedoms” of data subjects.
Microdesk Ltd. shall not export data to non-European Economic Area Countries without the data subject’s express consent.
Information asset register/data inventory/data mapping
Microdesk Ltd. is aware of the risks associated with the processing of particular types of personal data.
Microdesk Ltd. assesses the level of risk to individuals associated with the processing of their personal data and manages these risks accordingly.