JUST Digital Marketplace Ltd
To the requirements of ISO 27001:2017
Date of Version: 24/03/2020
Author: John Dean
Approved By: Christopher Badger
Confidentiality Level: Controlled: Uncontrolled if printed
This Supplier/Panel Member Security Policy is a controlled document and is maintained on the server as read only. The Information Security Officer will ensure that all amendments are circulated, and obsolete copies removed and filed. Hard copies used for training and internal auditing are controlled and distributed as follows.
Copy No. Holder
1 Information Security Officer
This document is reviewed periodically, at least annually, and is retained for a period of 5 years. Amendments and revisions are distributed to the named holders. The history of amendments and the issue of revisions are recorded below.
Copies of this document other than those listed above will not be revised; such copies will be marked as UNCONTROLLED.
Just understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, justdebt.co.uk (“Our Site”), and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under applicable law.
1. Important Information
(b) This website is not intended for children and we do not knowingly collect data relating to children under the age of 18.
2. Information About Us
(a) Our Site is owned and operated by Just Digital Marketplace Ltd (trading as Just), a private company limited by shares registered in England and Wales under company number 12146925 whose registered office is at c/o Smith and Williamson LLP, Portwall Place, Portwall Lane, Bristol, BS1 6NA.
(b) We are authorised by the Ministry of Justice Lord Chancellor’s department.
(d) Just Digital Marketplace Ltd is the controller and responsible for this website.
(e) We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights to such personal data, please contact the data privacy manager using the details set out below.
Name or title of data privacy manager: Chris Badger
Email address: firstname.lastname@example.org
Postal address: 1 Lyric Square, London, W6 0NB
Telephone number: 020 3848 9060
3. What Does This Policy Cover?
4. What Is Personal Data?
(a) Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
(b) Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymised data).
5. What Data Do We Collect?
(i) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
(ii) Contact Data includes billing address, delivery address, email address and telephone numbers.
(iii) Financial Data includes bank account and payment card details.
(iv) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
(v) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(vi) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(vii) Usage Data includes information about how you use our website, products and services.
(viii) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
(c) We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
(d) Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.
6. How is your personal data collected?
We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(i) apply for our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you; or
(v) give us some feedback.
(b) Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
7. How Do We Use Your Personal Data?
(a) Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Most commonly we will use your personal data in the following circumstances: (i) Where we need to perform the contract we are about to enter into or have entered into (performance of a contract);
(ii) Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (legitimate interest); or
(iii) Where we need to comply with a legal obligation (compliance with a legal obligation).
(b) Performance of Contract is processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract with us.
(c) Legitimate Interest is the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details in Part 2.
(d) Compliance with a legal obligation is processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
(e) Generally we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us in accordance with Part 2. The following table describes how we may use your personal data, and our lawful bases for doing so. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
8. Purposes for which we will use your personal data
(a) We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
(b) Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
(c) With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to protect your rights fully and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out by contacting us.
(d) Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 10. Please refer to Part 10for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor thedata that they collect and use themselves, and we advise you to check the privacypolicies of any such third parties.
(e) We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably consider that another purpose is compatible with that orthose original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 2.
(f) If we need to use your personal data for a purpose that is unrelated to, or in compatiblewith, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
(g) In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
9. How Long Will We Keep Your Personal Data?
(a) We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collect edit, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there isa prospect of litigation in respect of our relationship to you.
(b) To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
(c) By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction information) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data. See Part 11 for further information.
(d) In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. How and Where Do We Store or Transfer Your Personal Data?
(a) We may have to share your personal data with External Third Parties meaning:
(i) service providers based in the UK who provide payment, book-keeping, accountancy, IT and system administration services;
(ii) professional advisers acting as processors or joint controllers including accountants and auditors based in the UK who provide accounting and book-keeping services;
(iii) HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
(c) In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
(d) We will store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
(e) We may store or transfer some of your personal data within the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR and/or to equivalent standards by law.
(f) We may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
(i) we may share your data with affiliated companies or any company that forms part of our corporate group. This may involve the transfer of personal data outside the EEA and whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it that would apply under the Data Protection Legislation. Just ensures that personal data is protected by requiring all companies to which it is affiliated or otherwise grouped to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
(ii) we may share your data with external third parties, as detailed above, that are based outside of the EEA. The following safeguards are applied to such transfers:
(g) Please contact us using the details below in Part 2 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
(h) We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
(i) The security of your personal data is essential to us, and to protect your data we take a number of important measures, including the following:
(i) limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
(ii) procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
11. What Are Your Rights?
(a) Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
(vi) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(vii) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(viii) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(ix) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(x) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(xi) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(xii) Withdraw consent at any time. where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
(b) If you wish to exercise any of the rights set out above, please contact us.
(c) No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
(d) What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
(e) Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. How Can You Control Your Personal Data?
(a) In addition to your rights under the Data Protection Legislation, set out in Part 11, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/or by contacting the data protection manager at the point of providing your details).
(b) You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Can You Withhold Information?
(a) A Cookie is a small text/data file that is sent to your computer when you visit a website. Cookies collect information about users, such as their names, addresses, email, passwords and user preferences. When you visit the website again the cookie allows that site to recognise your browser. Whilst Cookies and the information they transmit may not identify an individual on their own, they may be able to do so in combination with other information held by us or a third party.
(b) We use the following cookies:
(i) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(ii) Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(iii) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(iv) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
(c) You may, if you wish, deny consent to the placing of Cookies, however certain features of Our Site may not function fully or as intended.
(d) In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose if you wish to disable Cookies. By default, most internet browsers accept Cookies, but this can be changed. Please consult the help menu in your internet browser or the documentation that came with your device.
(e) You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
(a) We may change this policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.