Data Protection Notice

1. Introduction

Convergence Communications Ltd (referred to as “we” “our” or “us”) is committed to protecting the privacy and security of your personal data and we have developed this data protection notice (“notice”) to inform you of the personal data we collect, what we do with your personal data, what we do to keep it secure as well as the Rights you have over your personal data.

Throughout this notice we refer to data protection legislation which includes the UK GDPR and Data Protection Act 2018, and other applicable laws including (but not limited to) the EU GDPR 2016, the Privacy Electronic Communication (EC Directive) Regulations (“PECR”) 2003 and the e-privacy Directive. This also includes any new or replacement legislation which may come into effect from time to time.

We are registered with the Information Commissioners Office (the ICO) under registration number ZB707660.

Our contact details are as follows:

Post:

Units 11-12 Hall Barn Road Business Park
Hall Barn Road
Isleham, Ely
Cambridgeshire
CB7 5RB

Telephone number: +44(0)1638 783620

Email address: info@convergencecomms.com

For any questions, complaints or concerns regarding data protection you can contact:

Philip Clayton-Smith, Operations Director

Email address: phillip@convergencecomms.com

2. Legal Basis

The legal basis for which we process personal data are:

• Consent
• Contractual obligation
• Legal obligation
• Vital interests
• Our legitimate interests

Also due to the nature of our organisation we may need to process special category personal data (e.g. health data for our internal HR practices). Where we process special category personal data, we will ensure the relevant special condition is identified and documented as required.

3. Data Subjects

Due to our business activities, we may process personal data of the following individuals (“data subjects”):

• Prospective customers
• Customers
• Social media users
• Job applicants
• Employees
• Vendor/Suppliers

The above list is representative and non-exhaustive.

4. Personal Data We Collect

The personal data we may process include:

• Name
• Postal address
• Email address
• Telephone number
• Job details (e.g. job title)
• Recruitment data (e.g. CVs)
• Call recordings
• IP address

The above list is non-exhaustive and representative.

5. How We Collect Personal Data

We collect personal data through different means such as:

• When you send us an enquiry via our website
• Register as a customer
• Contact us via telephone, email or letter
• Contact us on social media
• Apply to any of our job vacancies
• Through marketing lists (B2B data only)

The above list is representative and non-exhaustive.

6. How We Use Personal Data

We use personal data for the below activities:

• To communicate with you regarding our services
• To process job applications
• For our internal records
• To process any orders
• Issuing invoices
• Notify you of changes to our services
• To update and improve our website and services
• For any legal disputes and defend legal claims
• Marketing news and communications
• Handle any enquiries or complaints

The above list is non-exhaustive and representative.

7. Who We May Share Personal Data With

We do not sell, rent, or lease personal data pertaining to our customers (including prospective customers) at any time.

Due to the nature of our business, there may be times we are required to share personal data with other individuals/organisations. Examples of this can include (and is not limited to):

• Third party network providers
• Third party manufacturing companies
• External advisers (e.g. Legal, HR and Finance)

Where we are required to share data with third parties, we will work with them to ensure the correct data processor agreement/data sharing agreement is put into place as mandated under data protection legislation.

Please note there may also be instances where we may need to share personal data with a competent law enforcement body, regulatory body, government agency, court, or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation or (ii) to exercise, establish or defend our legal rights.

8. CCTV

We do not operate CCTV in and around our premises. If this was to change, we will update our notice as required.

9. Call Recordings

Calls into our telephone lines are recorded for training and quality control purposes. We will retain recordings in line with our data retention practices before they are deleted.

10. Live Chat

Our live chat facility on our website is administered by our team in the UK. After the chat has closed there is no saved history or logs on our side, so any chat history requests cannot be provided if ever requested. If this changes, we will update our notice as required.

11. Recruitment

We advertise job vacancies on websites such as Indeed or LinkedIn. We will process recruitment data such as CVs and any accompanying cover letters and will communicate directly with candidates during their application process.

We do not process any criminal conviction or offences data as part of our recruitment selection process, and we do not carry out a background screening checks on candidates either.

There may be instances of where we may need to process special category personal data, for example health information to help us make any reasonable adjustments for any in-person interviews should we ever be informed. We will request such information prior to confirmation of an interview so any reasonable adjustments can be made in advance. This data will also be held for as long as necessary in line with our data retention practices.

Please also note applications made on LinkedIn will enable our recruitment team to view your LinkedIn profile and view information not included on your CV.

12. Marketing and Social Media

We only conduct B2B marketing and contact those on our third-party mailing lists. Anyone who receives marketing emails can opt-out and unsubscribe (i.e. opt out) by clicking on the relevant unsubscribe link at the bottom of the email. You can opt out by contacting us directly using our details mentioned above.

We use social media sites such as Facebook, LinkedIn and Instagram to share news, updates and for promotional activities as a few examples. Our use of social media enables us to interact with customers (including potential customers), reach new audiences and showcase our products and services as a few examples. When you interact with us on social media through means such as “likes”, “shares” or leaving comments this enables us to see certain social media details (e.g. names, social media handles and photos). We don’t record or copy any social media profiles or details, but you should be aware when interacting with us on social media, other users or viewers can view your profile and any comments/feedback and it is your responsibility to ensure you have set up suitable and appropriate privacy settings for your use of social media.

13. Data Transfers Outside The UK

Due to the nature of our organisation there may be instances where we may need to transfer and share your data with other organisations (e.g. vendors or service suppliers) who are in the European Economic Area (The EU member states, Norway, Iceland, and Liechtenstein), in an adequate listed country or in other third countries who may not have robust or similar data protection laws to the UK/EEA. If we need to transfer your information where required, we will take steps to ensure that appropriate safeguards are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice.

14. Cookies

For details on the cookies, we use on this website and how you can change your consent, please see our cookie notice on our website.

15. Links To Other Websites

This website contains links to other websites, which are clearly marked as such. Please note that we have no control over external websites and are not responsible for the protection and privacy of any information which you may provide to them. Please refer to a website’s privacy notice when using it.

16. What Happens If Our Business Changes Hands?

We may from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will be permitted to use that data only for the purposes for which it was originally collected by us.

17. Data Retention

We will retain personal data to provide our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations, including our insurance requirements. We will also determine appropriate retention periods based on our legitimate interests where identified.

At the end of the retention period personal data will be securely deleted or anonymised where necessary. For more information to our data retention practices, you can contact us using our details above.

18. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

If we become aware of any loss, misuse, alteration of personal data we will work closely with our internal teams and other parties as necessary to investigate the incident and report (when needed to relevant parties) such instances.

19. Data Subject Rights

Under data protection law individuals have the following rights:

1. Right to be informed
2. Right to access personal data
3. Right to rectify personal data
4. Right to erase personal data
5. Right to object to personal data
6. Right to have data ported
7. Right to restrict personal data
8. Right to not have personal data processed by automated means and profiled

If you would like to enquire about these rights, how they apply and how they can be exercised please contact us using our details above.

20. Concerns and Complaints

If you have any concerns and/or complaints to this notice and/or to how we process personal data, please contact us using our details above.

You can make a complaint to the ICO (or other supervisory authority) at any time however, we hope that you would consider raising any issue or complaint you have with us first. You can submit a complaint to the ICO via https://ico.org.uk/make-a-complaint/.

21. Data Protection Notice Updates