EverChain UK aims to put in place appropriate technical and organisational measures to implement data protection principles and safeguard individual rights. We will do this as detailed under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
Personal data only includes information relating to natural persons who:
Article 5 of the GDPR sets out seven key principles which lie at the heart of the general data protection regime.
Article 5(1) requires that personal data shall be:
1. Processed lawfully, fairly and in a transparent manner in relation to individuals (lawfulness, fairness and transparency);
2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’)
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
5. Kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’)
6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘Integrity and Confidentiality’)
Article 5(2) adds that:
“The controller shall be responsible for, and be able to demonstrate compliance with paragraph 1 (‘accountability’).”
Principle 1 – What is the lawfulness, fairness and transparency principle and how does EverChain UK adhere to the principle?
Article 5.1 Processed lawfully, fairly and in a transparent manner in relation to individuals (lawfulness, fairness and transparency)
EverChain UK consider the lawful basis for processing data to be legitimate interests for the following reasons;
When EverChain UK collects its own personal data through the use of our own consumer-facing websites we will be using consent as the lawful basis for processing personal data.
Fairness means that we should only handle personal data in ways that people would reasonably expect and not use it in ways that have unjustified adverse effects on them. EverChain UK does not and will not obtain data in a manner that is not within our legitimate interests and has been obtained in a deceiving or misleading way.
Transparent processing is about being clear, open and honest with people from the start about who we are, and how and why we are using their personal data. EverChain UK makes it clear throughout our websites and communications, who we are, how we use personal data and why we are using personal data.
Principle 2 – What is the purpose limitation principle?
Article 5(1)(b) says
Personal data shall be:
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89 (1), not be considered to be incompatible with the initial purposes.”
EverChain UK must:
The purpose for collecting personal data, the use of information and contact from EverChain UK and third parties, is outlined in the privacy policy.
Principle 3- What is the data minimisation principle?
Article 5 (1)(c) says:
Personal data shall be:
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation)
EverChain UK collects the amount of personal data that is necessary for us to provide our professional services to our clients, such as name, contact details, business details, billing details etc.
Principle 4- What is the accuracy principle?
Article 5(1)(d) says:
Personal data shall be:
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regards to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)”
EverChain UK collects personal data that is filled out by a client and no personal data is altered. If a client enters the incorrect information on an application form, they can alter this information with us directly.
Principle 5 – What is the storage limitation principle?
Article 5(1)(e) says
Personal data shall be:
Kept in a form which permits the identification of data subjects for no longer than is for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with article 89(1) subject to implementation of the appropriate technical and organisational measures required by the regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’).
EverChain UK will retain information for as long as there is a business relationship with the customer. We will retain data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Principle 6 – What does the GDPR say about security?
Article 5(1)(f) of the GDPR concerns the integrity and confidentiality of personal data. It says that personal data shall be:
‘Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.’
This is the GDPR security principle which covers information security. EverChain UK operates an IT information security policy.
Principle 7- What is the accountability principle?
Article 5(2)
“The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (the other data protection principles)”.
EverChain UK approach to accountability include but is not limited to;
Article 24(1) of the GDPR says:
There are a number of processes that EverChain UK adheres to in order to maintain compliance with the GDPR including;
The Right to Be Informed
A request can come in writing via email or verbally on the phone from the customer or from a third party where the data came from. The customer or the third party will need to provide evidence and their desired solution.