RBR (“we”) is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all our legal obligations.
We hold personal data about our employees, participants, Associates, Partners, suppliers and other individuals for a variety of business purposes.
RBR is fully committed to ensuring continued and effective implementation of this policy.
1. GDPR The EU Regulation 2016/679, and any subsequent data protection legislation which may apply either in the United Kingdom, or worldwide.
2. RBR RBR Engineering Solutions Limited trading as 3D printing and engineering ("3DPE") a business registered in England number 09418298 whose registered address is at Bishopstone, 36 Crescent Road, Worthing West Sussex, BN11 1RL
3. “Associate” Any third party whether personal or corporate, with whom RBR has an express or implied contract or any form of legal relationship e.g. consultants, research bodies, and investors/directors
4. Business purposes
The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business purposes.
Business purposes include the following:
- fulfilling our contractual obligations
- Improving services
- Compliance with our legal, regulatory and corporate governance obligations and good practice
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
- Ensuring business policies are adhered to (such as policies covering email and internet use)
- Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting,
- Investigating complaints
- Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
- Monitoring staff conduct, disciplinary matters
- Marketing our business
5. Personal data
This is any information that relates to the data subject. Your name, your address, your age, your date of birth, your postcode, your telephone number, your email, just any data that is personal to you.
Personal data we gather may include: individuals' name, phone number, email address, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, and job title.
6. Special categories of personal data Special categories of personal data include information about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information —any use of special categories of personal data should be strictly controlled in accordance with this policy.
7. Data controller RBR is a Data controller. ‘Data controller’ means the person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
8. Data processor RBR staff and associates are Processors. ‘Processor’ means a person, agency or other body which processes personal data on behalf of the controller.
9. Processing ‘Processing’ means 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.
10. PII PII stands for Personally Identifiable Information, it is information by which a data subject can be identified directly or indirectly. If RBR has information about a data subject in its systems that may be used to identify it, RBR will ensure that how it stores and processes the information is compliant with the GDPR
11. Supervisory authority This is the national body responsible for data protection. The supervisory authority for our organisation is the Information Commissioners Office (ICO) www.ico.org.uk
12. Consent 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 on the Processing of Personal Data relating to him or her.
RBR complies with the Principles of data protection contained in the GDPR. The GDPR approach views the data subject as the owner of the data, and the data controller and processor as the data’s guardians. Therefore, we will make every effort possible in everything we do to comply with the GDPR principles. The Principles are:
Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
Limited for its purpose
Data can only be collected for a specific purpose.
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be as accurate and kept up to date as possible.
We cannot store data longer than necessary.
Integrity and confidentiality
The data we hold must be kept safe and secure.
Accountability and transparency
We will ensure accountability and transparency in all our use of personal data. We will show how we comply with each Principle. We are responsible for keeping a written record of how all the data processing activities we are responsible for comply with each of the Principles. This will be kept up to date and must be approved by the Data controller.
To comply with data protection laws and the accountability and transparency Principle of GDPR, we will demonstrate compliance. We are responsible for understanding our particular responsibilities to ensure that we meet the following data protection obligations:
Fully implement all appropriate technical and organisational measures
Maintain up to date and relevant documentation on all processing activities
Conducting Data Protection Impact Assessments as deemed necessary
Implement measures to ensure privacy by design and default, including:
Creating and improving security and enhanced privacy procedures on an ongoing basis
Fair and lawful processing
We will process personal data fairly and lawfully in accordance with individuals’ rights under the first Principle. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
If we cannot apply a lawful basis (explained below), our processing does not conform to the first principle and will be unlawful. Data subjects have the right to have any data unlawfully processed erased.
Lawful basis for processing data
We will establish a lawful basis for processing data. At least one of the following conditions will apply whenever RBR processes personal data:
We hold clear, explicit, and defined consent for the individual’s data to be processed
for a specific purpose.
The processing is necessary to fulfil or prepare a contract for the individual.
We have a legal obligation to process the data (excluding a contract).
Processing the data is necessary to protect a person’s life or in a medical situation.
Processing necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.
We will also ensure that, if your data is being processed by us, you are informed of the lawful basis for processing, as well as the intended purpose. This will occur via a privacy notice. This applies whether we have collected the data directly from you, or from another source.
Special categories of personal data
What are special categories of personal data?
Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination. The special categories include information about an individual’s:
biometrics (as used for ID purposes)
In most cases where we process special categories of personal data we will require your explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not
excessive, given the purpose for which it was obtained. We will not process personal data
obtained for one purpose for any unconnected purpose unless the individual concerned has
agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If we believe
that information is inaccurate you should record the fact that the accuracy of the information is disputed.
We will keep personal data secure against loss or misuse.
Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Storing data securely
In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it.
Printed data will be shredded when it is no longer needed.
Data stored on a computer will be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used.
Servers containing personal data must be kept in a secure location, away from general office space
Data will be regularly backed up in line with the organisation’s backup procedures.
All servers containing data will be protected by security software.
All possible technical measures will be put in place to keep data secure.
We will retain personal data for no longer than is necessary. What is necessary will depend
on the circumstances of each case, considering the reasons for which the personal data
Transferring data internationally
We will ensure that if we move data outside the EU it will be processed in a way that is compliant with GDPR. This includes cloud-based storage.
Rights of individuals
Individuals have rights to their data which we respect and comply with to the best of our ability. We ensure individuals can exercise their rights in the following ways:
Right to be informed
Providing privacy notices which are concise, transparent, intelligible and easily accessible, free of charge, that are written in clear and plain language.
Keeping a record of how we use personal data to demonstrate compliance with the need for accountability and transparency.
Right of access
Enabling individuals to access their personal data
Allowing individuals to be aware of and verify the lawfulness of the processing activities
Right to rectification
We will rectify or amend your personal data if requested because it is inaccurate or incomplete.
This will be done without delay, and no later than one month after we receive your request.
Right to erasure
We will delete or remove an individual’s data if requested and if there is no compelling legal reason for its continued processing.
Right to restrict processing
We will comply with any request to restrict, block, or otherwise suppress the processing of personal data.
We are permitted to store personal data if it has been restricted, but not process it further.
Right to data portability
We will provide you with your data if you ask us to, so that you can reuse it for your own purposes or across different services.
We will provide it in a commonly used, machine-readable format, and send it directly to another controller if requested.
Right to object
We will respect your right to object to data processing based on legitimate interest or the performance of a public interest task.
We will respect your right to object to direct marketing, including profiling (e.g. segmentation of data).
We will respect your right to object to processing your data for scientific and historical research and statistics.
Rights in relation to automated decision making and profiling
We will respect your rights in relation to automated decision making and profiling.
You retain their right to object to automated processing, to have the rationale explained to you, and to request human intervention.
Subject Access Requests
What is a subject access request?
You have the right to receive confirmation that your data is being processed, access to your personal data and supplementary information which means the information which should be provided in a privacy notice.
How we deal with subject access requests
We will provide you with a copy of the information that has been requested, free of charge. This will occur without delay, and within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats.
We will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a CSV file, although other formats are acceptable. We will provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to.
If complying with the request is complex or numerous, our Data controller can authorise extending the deadline by two months, but you must be informed within one month.
We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request that you specify the information you are requesting. For more information about how to make a Subject Access Request please visit ico.org.uk
Right to Erasure
1 What is the right to erasure?
You have a right to have your data erased and for processing to cease in the following circumstances:
Where the personal data is no longer necessary in relation to the purpose for which it was originally collected and / or processed
Where consent is withdrawn
Where you object to processing and there is no overriding legitimate interest for continuing the processing
The personal data was unlawfully processed or otherwise breached data protection laws
To comply with a legal obligation
The processing relates to a child
2 How we deal with the right to erasure
We can only refuse to comply with a right to erasure in the following circumstances:
To exercise the right of freedom of expression and information
To comply with a legal obligation for the performance of a public interest task or exercise of official authority
For public health purposes in the public interest
For archiving purposes in the public interest, scientific research, historical research or statistical purposes
The exercise or defence of legal claims
If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients.
The right to object
Individuals have the right to object to their data being used on grounds relating to their particular situation. We must cease processing unless:
We have legitimate grounds for processing which override the interests, rights and freedoms of the individual.
The processing relates to the establishment, exercise or defence of legal claims.
We will always inform you of your right to object at the first point of communication, i.e. in the privacy notice. We must offer you a way to object online.
The right to restrict automated profiling or decision making
We may only carry out automated profiling or decision making that has a legal or similarly significant effect on you in the following circumstances:
It is necessary for the entry into or performance of a contract.
Based on the individual’s explicit consent.
Otherwise authorised by law.
In these circumstances, we must:
Give you detailed information about the automated processing.
Offer simple ways for you to request human intervention or challenge any decision about you.
Using third party controllers and processors
As a data controller [(and/or) data processor], we will have written contracts in place with any third party [data controllers (and/or) data processors] that we use. The contract must contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
As a data processor, we must only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.
Our contracts will comply with the standards set out by the ICO and, where possible, follow the standard contractual clauses which are available. Our contracts with data controllers and/or data processors must set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
If you have any questions or concerns about anything in this policy, do not hesitate to contact our Data Controller.