The Purpose of this privacy statement is to explain how Perfect Pixel Plus processes personal data to fulfil its data protection responsibilities. This statement will be supplemented by ‘specific to client’ privacy notices when needed. The scope of this statement covers all related activities by the staff of Perfect Pixel Plus referred to as PPP for the remainder of this document.
The Role of PPP in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the PPP privacy manager (PM) to ensure that it is processed in accordance with the latest UK data protection legislation. You can contact the PM using claire@perfectpixelplus.co.uk. PPP is registered with the Information Commissioner’s Office (ICO).
The personal data processed by PPP will be basic contact information for the purposes of responding to general enquiries, business development, preparing contracts and setting up invoices. If PPP is not given all of the required personal data, it may result in an incomplete service being provided.
PPP’s duty of confidentiality means that PPP staff will treat clients’ personal data with due respect and in confidence. It is only disclosed to those that need to know it. PPP also expects the same duty of confidentiality of all third parties with whom it shares personal data. PPP uses reasonable organisational and technical measures to ensure personal data is kept secure.
PPP processes personal data against a lawful basis as described below:
To respond to your general enquiries and to promote our services, we will use our legitimate interests
To comply with our legal obligations
To fulfil our contractual obligations including their prior preparation
When processing a pre-defined purpose for which your consent has been sought and recorded prior to that processing commencing
In all cases the processing of personal data by PPP shall be:
Processed lawfully, fairly and transparently
Collected for specified, explicit and legitimate purposes
Adequate, relevant and limited to what is necessary (and no more)
Accurate and, when necessary, updated
Kept for no longer than is necessary
Processed in a manner that ensures appropriate security.
PPP will share personal data, but only when absolutely necessary, with some or all of the following third parties:
The Inland Revenue (HMRC)
An accountant appointed by us
Specified professional consultants in support of the service, notified at the time
Unspecified recipients but only when compelled to do so for legal reasons
PPP operates in a paperless environment where the first line processing takes place on standard office IT equipment based in and around the company’s registered premises. In addition, use is made cloud services such as Microsoft One Drive, Dropbox, Google Drive. PPP uses Xero accounting.
PPP follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:
Routine correspondence for casual enquiries in emails will be stored for one year
Service contract related data will be retained throughout the life of the engagement plus another 10 years following the termination of the contract
Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject
Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
By exception, documentation that includes personal data may be retained by PPP beyond the schedule, but only for a specific purpose and only when PPP believes there is a legitimate interest or a legal obligation to do so
At the end of the retention schedule PPP will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that PPP allows up to 3 months after the retention schedule to complete the action.
The PPP website uses cookies but visitors to the website are asked to consent to non-essential cookies before these are dropped – please see the separate cookie notice.
The PPP website links to appropriate business websites of interest. If these are used, you should be aware that the PPP has no responsibility for the control, content or handling of your personal data by these other websites.
The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:
Right to be informed as to how your personal data is being processed by PPP – this is done through this statement or specific to customer privacy notices
Right to access your personal data held by PPP which is done by making a ‘Data Subject Access Request’ (DSAR) to the privacy manager
Right to rectification of your personal data if you believe PPP has collected it incorrectly or it needs to be updated
Right to erasure of your personal data for which PPP no longer has a legitimate purpose to process
Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved
Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
Right to object to PPP processing your personal data for which it does not have a legal or contractual obligation
Rights related to automated decision making and profiling (however PPP does not use these techniques in its decision making)
Further details on your rights can be found on the ICO’s website: https://ico.org.uk.
Raising concerns, exercising rights or making queries about PPP’s processing of personal data can be done by contacting the privacy manager. Please be aware that we will need to determine your identity before responding fully, therefore, you may be asked for proof of ID or other material that, in context, will enable us to confirm your identity. Alternatively, you may wish to contact the ICO directly, using the details provided above.
