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Privacy Policy

Data Protection General Statement:

This Data Protection Policy outlines Be Secure (Jersey) Limited (“Be Secure”) commitment to its clients, staff, business partners, suppliers and other individuals to operate its business activities in a manner which meets the compliance obligations of the new Jersey legislation, the Data Protection (Jersey) 2018 Law (“DPJL”) and the General Data Protection Regulation (EU) 2016/679.

Be Secure understands and respects your right to privacy and we are committed to ensuring the confidentiality and security of your personal data and the personal data processing activities within our organization by applying the appropriate technical and organisational measures required to achieve this objective.

This document covers the policies and procedures for processing personal data in a compliant manner and outlines the rights of the data subjects (including clients, staff, intermediaries and other third parties) in respect of that data. The Privacy Notice below explains how we may use, process and store your personal data.

Data Controller:

Be Secure (Jersey) Limited is the data controller of all personal data and data processing activities of it’s data protection, information security and cyber security consultancy business activities operated from its office in Jersey, Channel Islands. Our registered office is located at 18 La Ville de L’Eglise, St. Peters, Jersey, JE3 7AR.

Be Secure (Jersey) Limited is registered as data controller with the Jersey Office of the Information Commissioner and its registered number is 59204.

Reference documents:

  • Data Protection (Jersey) Law 2018
  • Data Protection (Registration and Charges)(Jersey) Regulations 2018
  • The Data Protection (Bailiwick of Guernsey) Law, 2017.
  • EU General Data Protection Regulation 2016/679

Privacy Notice:

Scope of application:

This policy applies to our business activities operating in Jersey and Guernsey in the Channel Islands, UK and any professional services we conduct within the EU.

Personal data:

Personal data means any information relating to an identified or identifiable natural person.

Be Secure collects the following categories of personal information;

  • Name and address
  • Email address
  • Telephone number and other contact information
  • Company name (or equivalent) and address
  • Professional qualifications
  • LinkedIn profile information

Be Secure may also collect and process personal data to the extent that it is useful or necessary for the provision of our professional services as engaged by you.

Purposes of processing;

Be Secure uses this personal data for the following range activities,

Purpose

Lawful basis for processing

Client service work and DPO retained services

In the performance of client services undertaken by Be Secure under Contract when the client agrees to the Terms of Business and Letter of Engagement for each assignment

Building and managing client, intermediary and other relationships

Legitimate interest basis for Be Secure to operate their business to improve services offered to interested parties

You have the right to object to such processing by contacting our data protection representative

For the delivery of best practice Standards relating to client services

Legitimate interest basis for Be Secure to operate it’s business services to best practice standards

You have the right to object to such processing by contacting our data protection representative

Marketing client services, corporate and social events

Where Consent was received from interested parties

Consent maybe withdrawn by contacting our data protection representative

Managing security and access to the computer systems, premises, platforms, website and applications

Legitimate interest basis for Be Secure to protect it’s business computer systems, business premises and staff

You have the right to object to such processing by contacting our data protection representative

Recruitment of skilled consultancy staff and other support business staff

Legitimate interest basis for Be Secure to promote it’s business to attract suitably skilled staff

You have the right to object to such processing by contacting our data protection representative

Comply with legal, tax and regulatory obligations

In the performance of a task carried out in compliance with a Legal Obligation

Data collection methods:

We collect personal data in the following ways;

  • directly from you as a client, business partner, supplier or agent when engaging with us directly and/or
  • from third party channels such as public registers, social media networks, LinkedIn and its messaging service and any other public open forums
  • through the Be Secure website contact page

Information collected:

The personal data collected is used to meet consumer laws and other relevant laws and obligations, in the performance of the contract for services requested and where identified as assisting in the delivery of best practice standards of our business. Personal data may be used for legitimate business interest of Be Secure as indicated above.

Recipients of data:

Personal data collected may be disclosed or transferred to;

  • Be Secure’s data processors who provide services in relation to the running of its business systems
  • between group companies within the Be Secure group in performance of services
  • professional bodies and Be Secure’s business partners in the performance of services contracted and conducted under the necessary confidentiality, security obligations
  • competent authorities as required by law
  • other third parties where requested by you and when relevant consent has been obtained

Transfer and access to personal data:

Be Secure will only transfer data outside of the EEA where it is necessary for the performance of the contract agreed by you.

Where the destination of the data transfer is outside the EEA and does not include a third country that has an “adequacy/equivalence” status, as recognized by the EU Commission, we would always ensure that appropriate safeguards in place.

Where we cannot guarantee these safeguards, we would always request your consent before the data is transferred.

Retention of data:

Be Secure will only retain your personal data for as long as is necessary to fulfill the purpose for which it was collected.

Be Secure will retain data in relation to client engagements and transactions, supplier transactions and employee records for 10 years as required by the Company (Jersey) Law 1991.

Data subject rights:

Where a data subject wishes to exercise their rights under applicable data protection laws, they should contact the founder and director, Brian Siney on brian@besecure-consultants.com or 07797 738743.

Data subjects have a number of rights available;

  • access to your personal data,
  • rectification of any inaccuracies,
  • restriction on the processing your data
  • to object to the processing of your data
  • to be forgotten (erasure of your data)
  • right to data portability
  • right to object to automated decision making and profiling
  • right to withdraw consent for those data processing activities based on consent

Be Secure does not make any decisions based on purely automated means, but if we do, you have a right to object.

Making a complaint:

The Office of the Information Commissioner in Jersey, Channel Islands, is an independent statutory authority where you can make a complaint or learn more about data protection in Jersey. Their website is www.oicjersey.org and telephone number is 01534 716530.

Security features:

Be Secure is committed to ensuring the security of your personal data and has implemented appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data.

Be Secure employees and agents are trained in their data protection responsibilities and obligation to handle personal data in a confidential manner.

Third party websites

Users may find content on our Site that links to the sites and services of our clients, partners, suppliers, and other third parties. We do not control the content or links that appear on these third party sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies.

Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of this Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Change to this notice:

Be Secure may update this Privacy Notice at any time. The updated notice will appear on our website www.besecure-consultants.com and in our Terms of Business.

This Privacy Notice was last approved on 16 September 2018.

Contact details:

If you have any questions, concerns or complaints with respect to this Privacy Notice or the handling of your privacy or personal information, please contact the founder and director, Brian Siney on brian@besecure-consultants.com or 07797 738743.