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GDPR Website Privacy Policy

Last updated November 2023

Introduction

Welcome to the Intasite Limited’s Website Privacy Policy.

Intasite Limited (“Intasite”) respects your privacy and is committed to protecting your Personal Data. This privacy policy will inform you as to how we look after your Personal Data when you visit our website (regardless of where you visit it from), contact us and place an Order, and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

This privacy policy aims to give you information on how Intasite collects and processes your Personal Data through your use of our website, including any data you may provide through our website when you use our site forms, through speaking with a staff member on the phone or via email. This includes information that you give us when you subscribe to our Services (as defined in the terms & conditions), participate in any discussions via social media or report an issue with our Services or website.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Intasite is registered as a data controller with the Information Commissioner’s Office, which is the UK’s independent body set up to uphold information rights. As a data controller, we are responsible for ensuring that when we process Personal Information we comply with EU and UK data protection law and use it in accordance with our obligations.

We handle and process Personal Data belonging to our Clients (‘Clients who have contracted with us for the provision of health and Safety inductions and related services for End Users), Potential Clients (‘Clients who have made enquiries for the provision of Health and Safety inductions and related services for End Users), Suppliers and End Users (‘End Users are visitors to sites/premises, contractors or employees of the Client and are required to undertake and complete health and safety inductions and related services on our website’).

We do not use or share the Personal Data of the End Users except in limited situations such as forwarding the Personal Data and Special Category Personal Data to our Client or in exceptional circumstances whereby our IT providers require this information in order for us to perform our contract with our Clients. Please see below the grounds we rely on to do this.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Andrew Peter Murphy

Email address: [email protected]

Postal address: LevelQ, Surtees Business Park, Stockton on Tees, TS18 3HR

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in September 2020.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you and your Customers which we have grouped together as follows:

  • Identity Data includes your (including your staff, contractors and other internal bodies) and your Customer’s first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes your and your Customer’s billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details of your Customers.
  • Transaction Data includes details about payments to and from you and other details of products and services your Customers have purchased from us or you as our Client.
  • Technical Data includes internet protocol (IP) address, your login data, your URL click steam to and from the website, pages viewed, length of visit, response times of pages, ant errors, exit behaviour, 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 or your Customers use to access our website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you or your Customers use our website, products and services. When a Customer uses the Intasite platform, we collect data to make sure such Customers can identify a user when they visit a site and confirm they have a valid induction. We only collect information which our Customers have requested us to collect.
  • Marketing and Communications Data includes your or your Customers preferences in receiving marketing from us and our third parties and your communication preferences.
  • Medical Data includes medical history and next of kin, which we will only use in the case of an emergency.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We may collect Special Categories of Personal Data about you or your Customers, in particular medical and next-of-kin information. Where possible we will usually rely on a legal basis for processing this data other than explicit consent or consent if possible.

If you fail to provide Personal Data

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • 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:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. Please see our cookie policy at intasite.com/cookie-policy for further details.
  • Third parties or publicly available sources. We will receive Personal Data about you from various third parties as set out below:
  • Technical Data from the following parties:
  • Google Analytics which anonymously measures website visitors and their behaviour.
  • Apache log files from our servers. This will include your IP Address, page requested and details of your device.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Intuit, Quickbooks and Barclays Bank based inside and outside of the EU. Both of which are Privacy Shield companies which requires them to provide similar protection to Personal Data shared between Europe and the US
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your Personal Data (and that of your Customers) when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent, or your Customer’s 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.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your and your Customer’s Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new Client or Customer (a) Identity
(b) Contact 		Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to you		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey 		a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications 		(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how our Clients and their Customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications 		(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how Customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical 		(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 		Necessary for our legitimate interests (to study how Customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, Customer relationships and experiences (a) Technical
(b) Usage 		Necessary for our legitimate interests (to define types of Clients and Customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications 		Necessary for our legitimate interests (to develop our products/services and grow our business)
To pass on to medical professionals in case of an accident on-site (a) Identity
(b) Contract
(c) Medical 		Necessary to protect your vital interests

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You (and/or your Customer) will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party Marketing

We will get your or your Customer’s express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you or a Customer opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see intasite.com/page/privacy-policy/

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Andy Murphy at [email protected]

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

5. Disclosures of your personal data

We may share your Personal Data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

6. International transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data, and your Customers, will involve a transfer of data outside the EEA.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

7. 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.

We have put in place procedures to deal with any suspected Personal Data breach. These include the use of complex passwords, built in firewalls to block external connections from untrusted sources on all servers and computers in our offices. Our router also has a built-in firewall. There is limited physical access to the building as staff members must use their key fob at 3 separate stages to get into the office. Doors are automatically locking and can only be unlocked with each staff member’s key fob.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my Personal Data for?

We will only retain your and/or your Customer’s Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, reporting requirements. or where it is necessary to do so for our contractual, sales and marketing purposes.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In any case, Intasite’s marketing manager ensures that marketing databases are checked against industry suppression files every six months.

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.

We may also cease to store Personal Data if in our reasonable opinion, it is no longer necessary to store the data for the purposes set out in the table above.

In addition, even though it may continue to be necessary for us to store Customer or Client Personal Data for the purposes as set out, we may delete the data earlier than as set out above if:

  • after carrying out internal reviews we feel that the risk to Personal Data or Customer personal data rights outweighs the security measures that we are able to implement; or
  • after carrying out internal reviews, we believe that the Personal Data may be out of date or inaccurate and we are unable to verify this with the Client or Customer.

By law we have to keep basic information about our Customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being Customers for tax and legal purposes.

In some circumstances you can ask us to delete your data: see below for further information.

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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

  • [Request access to your personal data].
  • [Request correction of your personal data].
  • [Request erasure of your personal data].
  • [Object to processing of your personal data].
  • [Request restriction of processing your personal data].
  • [Request transfer of your personal data].
  • [Right to withdraw consent].

If you wish to exercise any of the rights set out above, please contact us.

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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 [email protected].

Performance of Contract means 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.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Customer: a person from whom Intasite is instructed by the Client to facilitate the provision of Services in accordance with the Order

THIRD PARTIES

Internal Third Parties

  • Other companies such as Middlesbrough Council who provide IT and system administration services, should there be a problem with the building’s internet or IT.

External Third Parties

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based who require reporting of processing activities in certain circumstances.
  • Subcontractors, payment services, advertisement networks, analytics providers, search engine and server providers such as Digital ocean, Amazon and Cloudflare
  • Twilio and SendGrid who send transactional email and SMS messages for functions on the Intasite platform.
  • Vimeo who host induction videos for functions on the Intasite platform
  • Amazon S3 private bucket based in the EU (Ireland). Daily backups are made of the database by an automated backup system, which are stored securely at this site for disaster recovery. These backups are stored and are automatically erased after 30 days. Backups are also transmitted to Amazon S3 over an encrypted connection.

YOUR LEGAL RIGHTS

You have the right to:

  • 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.
  • 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.
  • 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.
  • 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.
  • 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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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.
  • 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.