PRIVACY POLICY

We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a complaint.

 

WHO WE ARE

Kangaroo Self Storage Ltd trading as Smart Storage Ltd (“we”, “us”) is the operator of the website www.smart-storage.co.uk. We collect, use and are responsible for certain information about you. When we do so, we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

 

THE PERSONAL INFORMATION WE COLLECT AND USE

Personal information provided by you

In the course of operating our self storage business, we collect personal information when you provide it to us, such as your name, postal address, email address, phone numbers, date of birth and payment details.

We also collect personal information from you if you apply for a job with us or work for us for any period of time. In this context, personal information we gather may include: contact details, financial and payment details, details of education, qualifications and skills, marital status, nationality, NI number, job title, and CV.

Our website also uses cookies (see our Cookies Policy) and collects IP addresses (which means that we can uniquely identify a specific device using our site.

Personal information provided by third parties

Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us provide services to you and to improve and personalise our service to you. If you apply for a job with us, we may receive information from the people who provide references.

Personal information about other individuals

If you give us information on behalf of someone else as an alternate contact, referee or next of kin, you confirm that the other person has agreed that you can:

Sensitive personal information

We will not usually ask you to provide sensitive personal information. We will only ask you to provide sensitive personal information if we need to for a specific reason, for example, if we believe you are having difficulty dealing with your account due to illness. If we request such information, we will explain why we are requesting it and how we intend to use it.

Children

We do not knowingly collect personal data relating to children under the age of 16. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us. We will ask you to prove your relationship to the child but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.

 

HOW AND WHEN DO WE COLLECT INFORMATION FROM YOU?

We gather information directly from you face to face if you come to our site for information or to sign a storage agreement and over the telephone if you ring us to make an enquiry.  We collect personal information via our website and other technical systems. We collect this when you use our website or Apps to sign up to, participate in or receive a service from us, such as requesting a quote online or entering a live chat. Our website also uses cookies (see “Use of cookies” section below) and collects IP addresses (which means a number that can uniquely identify a specific computer or other device on the internet). We also collect personal information when you contact us, send us feedback, sign up to newsletters, complete customer surveys and participate in competitions.

We may monitor and record communications with you (such as telephone conversations and emails).  We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.

If you visit our storage facility, some personal data may be collected from monitoring devices and systems such as closed circuit TV (CCTV) and door entry systems at the site.

 

Use of Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device such as a mobile telephone or tablet) when you use our website. We use cookies to track and profile customers such as action tags and pixel tracking on our website to assist our marketing. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify you individually. We use analysis software to look at IP addresses and cookies to improve your experience as a user of our website. We do not use this information to develop a personal profile of you. If we do collect personally identifiable information, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it and you will be able to opt in to receive this.

You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on our use of cookies, please see our Website cookie policy.

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

 

REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION

We rely on a different lawful basis for collecting and using personal data in different situations.

 

Contracts

Where you make enquiries about storing with us before you become a customer, we need to collect personal information about you so that we can take steps to enter into a contract with you.  Once you have become a customer, we need to collect and use personal information to provide services to you and to claim our right to be paid in return for our services under our standard terms of business/contract with you.  This includes collecting and using your personal information to:

 

Job Applications

If you apply for a job with us, we will collect and use personal information to process your application and check references.  If you take a job with us, we will collect and use your personal information to enter into an employment contract with you and to administer the employment relationship, including making payments to you, accounting for tax, ensuring safe working practices, monitoring and managing staff access to systems and facilities, monitoring absences and performance and conducting assessments.

 

Legal Obligations

We collect and use personal information from our customers and staff to comply with our legal obligations.  For example, we will take copies of documents that identify you so that we can comply with anti-money laundering and counter-terrorist financing requirements.

 

Legitimate Business Interests

Our priority is to make sure we give a high quality and secure service to customers and to follow up effectively on enquiries even though we accept that not all enquiries will lead to a business relationship or contract.  We collect personal information to:

 

CCTV Recordings

It is a key feature of our storage service that we operate CCTV within the storage facility.  We collect and process CCTV images

 

Credit Checking

We may do a credit check on you so that we can make credit decisions about you and people or businesses associated with you. These checks may also be used to help prevent and detect fraud and money laundering.

Our search will be recorded on the files of the credit reference agency.

We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address or who are financially linked to you.

Other credit businesses may use your information to make credit decisions about you and the people with whom you are financially associated, trace debtors, and prevent and detect fraud and money laundering.

If you provide false or inaccurate information to us and we suspect fraud, we will record this.

If you want to see your credit file, please contact our central office to obtain the contact details of the credit reference agency which we use.

 

When will we contact any other person about you?

If you provide us with details of any other person we can contact to discuss your account, we may contact that person and discuss and share the details of your account with that person and deal with that person in relation to your account as if that person was you.  We may particularly want to do this if we are unable to get in touch with you for any reason. If you change your mind, you can email or write to us and have this person taken off your account as an alternate contact person (see ‘How can you contact us?’ below).

If you provide us the details of a person who we can contact for a job reference, we may contact that person in connection with your job application.

 

Marketing

We will also communicate with you information about other services we can offer you and update you about our activities and promotions which may be of interest to you. If you would like to stop receiving these email newsletters, you can also click on the “unsubscribe” button at the bottom of the email newsletter. It may take a few days for this to take place. See ‘What rights do you have?’ below for further information. If you ask us to stop contacting you in this way, you can also ask us to start again at any time.

If we propose to use your information for any other uses we will ensure that we notify you first. If we need your consent to use your information for these other purposes, we will give you the opportunity to opt in or to refuse.  If you opt in, you will be able to opt out at any time.

 

Who your information might be shared with

We will not sell or use your information to any other company or third party for marketing use.

We may disclose your personal data to:

If we pass data on to insurers, they may enter your data onto a register of claims which is shared with other insurers to prevent fraudulent claims. If we use an outside party to process your information, we will require them to comply with our instructions in connection with the services they provide for us and not for their own business purposes.

 

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.  We limit access to your personal information to those who have a genuine business need to know it.  Those people processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We will use technical measures to safeguard your personal data, for example:

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

While we will use all reasonable efforts to keep your personal data safe, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).

Our website contains links to websites and applications owned and operated by other people and businesses. These third party sites have their own privacy policies and use their own cookies and we recommend that you review them before you provide them with personal information.  They will tell you how your personal information is collected and used whilst you are visiting these other websites.  We do not accept any responsibility or liability for the content of these sites or the use of your information collected by any of these other sites and you use these other sites at your own risk.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

 

TRANSFERS OF YOUR PERSONAL INFORMATION OUT OF THE EEA

We may transfer your personal data to the United States of America for the purpose of data storage when using MailChimp (privacy policy can be seen here) and our CRM software SiteLink (privacy policy can be seen here). Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data. If you would like further information, please contact us (see “How to contact us” below).

 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will usually hold your personal information as a customer or employee on our system for the period we are required to retain this information by applicable UK law, currently 6 years from the end of our contract or 6 months after any unsuccessful job application, unless you have told us you want us to delete the information earlier (see section “What rights do you have” below).

 

WHAT RIGHTS DO YOU HAVE?

Under the General Data Protection Regulation you have a number of important rights. These include the following rights:

Further information on each of these rights is available from the Information Commissioner’s Office.

If you would like to exercise any of these rights, please:

We will not charge any fee for any of these services in most cases.

 

HOW TO CONTACT US

We hope that we can resolve any query or concern you raise about the way we use your personal information Please contact us if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us, please send an email to headoffice@kangarooselfstorage.co.uk or write to us at 21 Sidegate, Haddington, East Lothian, EH41 4BZ or call us on 0800 012 1528.

The General data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority I the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone 0303 123 1113

 

CHANGES TO THE PRIVACY POLICY

This Privacy Notice was published on 11th May 2018 and last updated on 11th May 2018. We may change this Privacy Notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.

 

DO YOU NEED EXTRA HELP?

If you would like this policy in another format (for example: audio, large print, braille) please contact us (see ‘How can you contact us?’ above).

 

DATA PROTECTION POLICY

Introduction

We hold personal data about our employees, customers, suppliers and other individuals for a variety of business purposes.

We take seriously our obligations under the General Data Protection Regulation (GDPR) and all other relevant regulation and legislation in relation to the personal data we hold.

We have appointed Helen Bower as our Data Compliance Manager (DCM) to have overall responsibility for monitoring how we collect and use personal data, data security and compliance with data protection regulations and laws.

This policy sets out how we seek to protect personal data and ensure staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the DCM should be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Definitions

It is important that you understand the following terms:

Business purposes—the purposes for which personal data may be used by us, eg creating and administering customer accounts, personnel, administrative, financial, regulatory, payroll and business development purposes. These include the following:

Scope

This policy applies to all staff. You must be familiar with this policy and comply with its terms.

We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

Who is responsible for this policy?

The DCM has overall responsibility for this policy and for ensuring this policy is adhered to by all staff.

Legal responsibilities

The GDPR imposes requirements that:

Our procedures

Fair and lawful processing – Privacy Notices

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the processing is:

In most cases this provision will apply to routine business data processing activities for our Business purposes.

Our Privacy Notice is a notice to customers on data protection. The notice:

Our Privacy Notice needs to be given to the customer at the first point of contact. Our website will direct customers to our Privacy Notice when they make an enquiry on-line. If a customer makes an enquiry in the store or signs up a licence agreement in store, then you must give them a copy of our Privacy Notice at that time.  If enquiries are made by telephone, you will need to let them know we take the privacy of their data seriously and let them know that they can view our Privacy Notice on-line or we can send it to them by post or email.

Sensitive personal data

In almost all cases where we process sensitive personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply, or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

Accuracy and relevance

We will ensure that any personal data we process is accurate, adequate, relevant and not excessive given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them and we need to respond to them within one month. If any person makes a request to correct inaccurate information, you must inform the DCM immediately giving details of the request. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and pass this on to the DCM when you report that the request has been made.

Right to stop direct marketing

You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DCM about any such request.

Do not send direct marketing material to someone electronically (e.g. via email) unless the person has given their consent to this. Yo u will need to follow industry guidance on following up on people who have made enquiries or asked for a quote for storage. [Please see our Policy on following up potential customers.]

Please contact the DCM for advice on direct marketing before starting any new direct marketing activity.

Right of access to personal data – subject access requests

Please note that under the Data Protection regulations, individuals are entitled (subject to certain exceptions) to request access to information held about them.

If you receive a subject access request, you should refer that request immediately to the DCM. We may ask you to help us comply with those requests.

Please contact DCM if you would like to correct or request information that we hold about you. We will respond to your request within 30 days. There are also restrictions on the information to which you are entitled under applicable law.

Right to be forgotten or to restrict use of personal data

Please note that under the Data Protection regulations, individuals are entitled (subject to certain exceptions) to request that we restrict how we use the personal information we hold about them or that we delete it altogether.

If you receive a request of this kind, you should refer that request immediately to the DCM. We may ask you to help us comply with those requests.

Your personal data

You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required, e.g. if your personal circumstances change then please inform the DCM so that they can update your records.

Data security

You must keep personal data secure against loss or misuse. This means you should comply with our security guidelines and policies set out in the Information Security Schedule below.

Where other organisations process personal data as a service on our behalf (e.g. payroll or outsourcing companies), the DCM will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

Data retention

We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our Data retention guidelines.

Transferring data internationally

There are restrictions on international transfers of personal data. You must not transfer personal data internationally at all without first consulting the DCM

Reporting breaches

All members of staff have an obligation to report actual or potential data protection compliance and data security failures. This allows us to:

If you suspect or become aware of any data security breach or that we have failed to do something which may be a breach of our data compliance obligations, you should report these facts or your suspicions immediately to the DCM.

Training

All staff will receive training on this policy. New employees will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.

Training will cover:

Completion of training is compulsory.

The DCM will continually monitor training needs but if you feel that you need further training on any aspect of the relevant law or our data protection policy or procedures, please contact the DCM.

Monitoring

Everyone must observe this policy. The DCM will take steps to ensure it is being adhered to.

The DCM will review this policy at least annually to ensure it remains fit for purpose and compliant with the applicable legislation.

Consequences of failing to comply

 

INFORMATION SECURITY SCHEDULE

Introduction

The IT Support Company will review security event logs and error logs on a monthly basis and is responsible for downloading and installing any necessary software, security patches or system updates.

Our procedures

Information management

Human resources information

Access to offices and files

Computers and IT

Backup of data

Communication and transfer

Personal email and cloud storage accounts

Home Working

Cybercrime prevention and management

IT system management and development

Our IT systems are managed by suitably trained staff who are responsible for overseeing day-to-day operation and to ensure continued security and integrity.

The IT Support Company is responsible for ensuring we have procedures for the secure configuration of network devices. These will vary from time to time but are likely to include:

The IT Support Company and the Managing Director are responsible for the management of user accounts and will implement procedures to ensure:

Access controls will be maintained at appropriate levels for all systems by ongoing and proactive management. Any changes to permissions must be approved by the IT Support Company or the Managing Director.

New IT systems, or upgrades to existing systems, must be authorised by the Managing Director or the Group Operations Manager and the authorisation process must take account of security requirements. The information assets associated with any proposed new or updated systems must be identified and a risk assessment undertaken.

Any new equipment must have appropriate levels of resilience and fault tolerance and must be correctly maintained.

Software and applications must be managed to ensure their smooth day-to-day running and to preserve data security and integrity. The purchase or installation of new or upgraded software must be planned and managed and any information security risks must be mitigated. Specifications for new software or upgrades of existing software must specify the required information security controls.

Business continuity

The business has in place a Business continuity plan. That plan has been designed to ensure continued data security and to maintain confidentiality. You will be trained on what to do if this plan needs to be put into place.

Reporting breaches

If you suspect or become aware of any data security breach or that we have failed to do something which may be a breach of our data compliance obligations, you should report these facts or your suspicions immediately to the DCM.