1 About OCM Business Systems Ltd
In this policy, whenever you see the words ‘we’, ‘us’, ‘our’ or ‘OCM', it refers to OCM Business Systems Ltd who have built a reputation on successfully providing high quality IT & EPoS asset disposal services, uniquely tailored to our customers’ needs. As a result, we have become the first choice IT asset management partner of banks and financial institutions, major retailers, multi-nationals, government departments and public sector organisations.
We are a ‘Private Limited Company’ for the purposes of the General Data Protection Regulations (GDPR) and this privacy statement sets out our data processing practices.
We store and process personal data (information that relates to and identifies living people) as part of our business operations as an ITAD. We are registered with the Information Commissioners Office (registration number Z7511006, please see http://ocmbiz.com/accreditations) and have dedicated data controller and data protection lead.
If you have any questions in relation to our Privacy Statement, or how we use your personal data they should be sent to firstname.lastname@example.org or addressed to Data Protection, OCM Business Systems Ltd, 2 Ascot Road, Pershore, Worcs, WR10 2JJ.
2 Personal data we collect and how we use it
We’ll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (GDPR), the Data Protection Act 2018 and Privacy of Electronic Communication Regulation.
As a controller, we will collect and use your personal data (this means any information which identifies you, or which can be identified as relating to you personally, such as your name, address, phone number, email address or IP address). We’ll only collect the personal data we need and we’ll make it clear at the point of collection why we are collecting it.
Personal data provided to us will be used for the purpose or outlined in this Privacy Statement in a transparent manner at the time of collection, in accordance with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
As a processor, OCM will be working under instruction of a Data Controller. The primary process will be to securely erase or destroy any data left on devices sent for recycling. Data will be collected and stored as part of the process, but at no time will the data be accessed for viewing.
“Your privacy is important to us, so we’ll always keep your details secure”.
Your personal data [any information which identifies you, or which can be identified as relating to you personally, Eg. your name, address, phone number, or email address] will be collected and used by us.
“We will only collect the personal data that we need to carry out our role”.
We collect personal data in connection with our business activities, in most cases OCM have no access to the data held on IT or EPoS assets received.
The ways you can give us your personal data include filling in forms on our website, or by corresponding with us [by phone, email, face to face or letter], or other social media functions on our website.
Personal data provided by you
The personal data you give us may include your name, title, address, employment status/role, demographic information, email address and telephone numbers.
“We will never share your personal data without your explicit consent [except in circumstances where the law may require us to do so e.g. your ‘vital interests’ or the suspected commission of crime]”
We may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. If you access our website via your mobile device, we will collect your unique phone identifier.
Special Category Data
‘Special Category Data’ is personal data which the GDPR says is more sensitive, and so needs more protection. It includes data about your health and wellbeing and in the unlikely event that OCM process special category data OCM have policies and procedures in place to ensure this information is secure. We will not process special category data without consent.
2.1 Information & Proposals
In providing information or a proposal to you there may be occasions when we will need to record your personal information. For example, if you call us for information or a proposal and we cannot deal with your enquiry at the first point of contact, we will record your personal information and only hold the details for the duration of the enquiry.
We will always act upon your choice of how you want to receive communications [for example, by email, post or phone].
We would like to use your details to keep in touch through our newsletter about ITAD related issues and events that may matter to you. We will only send our newsletter to you if you agree to receive it.
‘We will never share your information with other businesses for inclusion in their marketing’
If you agree to receive our newsletter from us, you can change your mind later. However, if you tell us you do not want to receive our newsletter then you may not hear issues or events that may be important to you.
We may sometimes use third parties to capture some of our data on our behalf. We will only do this where we are confident that the third party will treat your data securely, in accordance with our terms and in line with the requirements set out in the GDPR.
2.2 Gathering data relating to ITAD services
Any personal data we collect in relation to providing ITAD services will be entered into our data base which has been designed to record the relevant information. We need to use that data to provide relevant services.
2.3 Recruitment and Employment
To comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data, from job applicants and employees. Such data can include, but is not limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it’s processed is given below:
Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.
Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.
Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, training and development, absence, disciplinary matters, e-mail address and telephone number.
Sensitive Personal Data
‘Sensitive personal data’ is defined as information about racial or ethnic origin, political opinions, religious beliefs or other similar beliefs, trade union membership, physical or mental health, sexual life, and criminal allegations, proceedings or convictions.
In certain limited circumstances, we may legally collect and process sensitive personal data without requiring the explicit consent of an employee. For example:
- We will process data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and, where necessary, consent.
- We will process data about, but not limited to, an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for monitoring and upholding our equal opportunities policies and related provisions.
- Data about an employee’s criminal convictions will be held as necessary.
- Disclosure of employees’ personal data to other bodies
We may share an employee’s data with other bodies in the following circumstances:
- To carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more third party supplier.
- To meet the employment contract, we are required to transfer an employee’s personal data to third parties, for example, to pension providers and HM Revenue & Customs.
- To fulfil our statutory responsibilities, we’re required to give some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.
3 Disclosing and Sharing Information
We will only share your identifiable information with those organisations when we have your express consent to do so.
When we allow third parties acting on behalf of OCM to access to your information, we will always have complete control of what they see, how long they see it for and what they are allowed to do with it. We do not sell or share your personal information for other organisations to use.
Personal data collected and processed by us may be shared with the following groups where necessary:
- OCM employees and Directors
- Third party cloud hosting and IT infrastructure providers who host the website and provide IT support;
Also, under strictly controlled conditions:
- Service Providers providing services to us
4 Your Data Protection Rights
Individuals have rights over their personal data, we as a controller of your personal data, are responsible for fulfilling these rights.
4.1 Withdrawal of Consent
Where OCM is using your personal data based on your consent, you have the right to withdraw that consent at any time. You also have the right to ask OCM to stop using your personal data for direct marketing purposes.
If you want to withdraw your consent or ask us to stop using your personal data tell us by contacting email@example.com
4.2 Subject Access Request
You have the right to access personal data held by us. This right may be exercised by writing to or emailing our Data Protection Officer.
You will be asked to provide the following details:
- The personal information you want to access;
- The date range of the information you wish to access
We will also need you to provide information that will help us confirm your identity. OCM will accept two from three following forms of ID when information on your personal data is requested:
- driving license, passport,
- birth certificate
- utility bill not older than three months.
Once we have all the information necessary to respond to your request we’ll provide your information to you within 30 days.
4.3 Right to amendment of personal data
We want you to remain in control of your personal data. If, at any time, you want
to update or amend your personal data or marketing preferences please contact
us in one of the following ways:
Call: 01386 555008
OCM Business Systems Ltd,
2 Ascot Road,
Updates will take place within 30 days of request.
4.3 Other data subject rights
As an individual you have further rights regarding your personal data, such as the right to erasure (right to be forgotten), the right to restrict or object and the right to data portability. There may be other legal reasons why we need to process your personal data but let us know if you don’t think we should be using it. If you would like to exercise any of these rights, please contact OCM using one of the above methods.
5 Keeping your Information Safe
Information system and data security is imperative to us to ensure that we are keeping our customers, employees and contractors safe.
We operate a robust and thorough process for assessing, managing and protecting new and existing systems which ensures that they are up to date and secure against the ever-changing threat landscape. In addition to this, we follow a defence in depth security model, which means that your data is protected by multiple layers of security.
OCM takes cyber security seriously and has achieved the Cyber Essentials accreditation, and is registered in the national database which can be found here.
Our staff complete mandatory information security and data protection training on employment and annually thereafter to reinforce responsibilities and requirements set out in our information security policies.
When you trust us with your data we will always keep your information secure to maintain your confidentiality. By utilizing strong encryption when your information is stored or in transit we minimize the risk of unauthorized access or disclosure; when entering information on our website, you can check this by right clicking on the padlock icon in the address bar.
Where possible all data is stored in the UK, and due diligence is carried out to make sure any services have the correct information security in place such as ISO 27001 and at least Cyber Essentials.
We may transfer your personal information outside of the European Economic Area. Where we do so we ensure appropriate safeguards are in place.
We use ‘Mailchimp’ to carryout email marketing, your data is transferred to Data Centres located in the USA. Under GDPR regulations any business operating in USA must have Privacy Shield in place to comply with GDPR. ‘Mailchimp’ has obtained Privacy shield which can be found at Mailchimp Privacy Shield
We will only use and store your information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory legal requirements.
Most web browsers allow some control of cookies through the browser settings. To find out more about cookies, including how to see what have been set and how to manage and delete them, visit www.allaboutcookies.org.
7 Links to other websites
8 What to do if you’re not happy
In the first instance, please talk to us directly so we can resolve any problem or query. You also have the right to contact the Information Commissioner’s Office (ICO) if you have any questions about Data Protection. You can contact them using their help line 0303 123 113 or at www.ico.org.uk.
10 Our Data Protection Lead
Our Data Protection lead can be contacted in the following ways:
OCM Business Systems Ltd,
2 Ascot Road,
Or email: firstname.lastname@example.org
See What Our Customers Say
We have become the first choice IT asset management partner of financial institutions, major retailers, multi-nationals and public sector organisations
“Having worked with OCM for some years, I can confidently state that their approach to customer service is exemplary. Our account manager is always highly responsive, very friendly, and consistently helpful, even if some of our requests are troublesome! OCM are a pleasure to partner with, I would not hesitate to recommend them.”
IT Service Delivery Director
“We use OCM as our recycling partner not just because they are good at recycling our unwanted IT equipment or because they follow good practices and standards to ensure we comply with the regulations. For us we use OCM over other recycling companies because of their commitment to raising money for local and national charities. Since our relationship with OCM began many years ago, we have raised tens of thousands of pounds. Our account manager is a pleasure to work with and he has personally helped to raise thousands for a local charity. As a company and as a collection of people, I would highly recommend working with them.”
Head of Technology Support
“We had limited time and resource to collate all equipment from various floors and OCM managed to sort in type order, identify data items and preparation for collection. Very happy with the asset reporting detail provided and erasure ID information”