At Avita Tech Ltd trading as Avita Group (“Avita/We/Us/Our”), safeguarding your privacy is a top priority. We are dedicated to collecting, processing, and using your personal data in accordance with this notice and in compliance with UK laws. The term “personal data” is defined by Article 4(1) of the UK General Data Protection Regulation (GDPR).
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- How to complain
Post
Avita Tech Ltd, 1 Clock House Road, Beckenham, Kent, BR3 4JS
Telephone
020 8663 0077
Email
gdpr@avitagroup.co.uk
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Pronoun preferences
- Occupation
- Transaction data (including details about payments to and from you and details of products and services you have purchased)
- Information relating to compliments or complaints
- Video recordings
- Audio recordings (e.g. calls)
- Records of meetings and decisions
- Account access information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Marketing preferences
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
- Names and contact information
- Video recordings of public areas
- Audio recordings of public areas
- Video recordings of private or staff only areas
- Audio recordings of private or staff only areas
- Dashcam footage – outside vehicle
- Dashcam footage – inside vehicle
- Financial information e.g. for fraud prevention or detection
- Location data
We collect or use the following personal information for information updates or marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
- Purchase or account history
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Health and safety information
- Any other personal information required to comply with legal obligations
- Safeguarding information
We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
- Trade union membership
- Health information
We collect or use the following personal information to protect client welfare:
- Names and contact information
- Emergency contact details
We collect or use the following personal information for recruitment purposes:
- Contact details (e.g. name, address, telephone number or personal email address)
- Date of birth
- National Insurance number
- Copies of passports or other photo ID
- Employment history (e.g. job application, employment references or secondary employment)
- Education history (e.g. qualifications)
- Right to work information
- Details of any criminal convictions (e.g. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Security clearance details (e.g. basic checks and higher security clearance)
We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
- Trade union membership
- Health information
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Addresses
- Payment details
- Purchase or service history
- Video recordings of public areas
- Audio recordings of public areas
- Video recordings of private or staff only areas
- Audio recordings of private or staff only areas
- Call recordings
- Dashcam footage – outside vehicle
- Dashcam footage – inside vehicle
- Witness statements and contact details
- Relevant information from previous investigations
- Customer or client accounts and records
- Financial transaction information
- Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Where existing products or services are improved by the vendor, we believe clients may benefit from this improvement. Where new products and services are created by the vendor, we believe clients may benefit from using these new products and services where they are similar to existing products or services used by the client.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Where clients use third parties we believe it\’s beneficial to our clients\’ and third parties\’ to record those relationships for the purposes of being able to fulfil our obligations for our products and services, such as support services.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
- Recognised legitimate interests – our pre-approved purpose for collecting or using personal information for the operation of client or customer accounts:
We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’).
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Where notices are produced by the vendor we may need to communicate these to our clients, such as product recalls. Where existing products or services are improved by the vendor, we believe clients may benefit from this improvement. Where new products and services are created by the vendor, we believe clients may benefit from using these new products and services where they are similar to existing products or services used by the client.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to protect client welfare are:
- Recognised legitimate interests – our pre-approved purpose for collecting or using personal information to protect client welfare:
We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for recruitment purposes are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Recognised legitimate interests – our pre-approved purpose for collecting or using personal information for recruitment purposes:
We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Where we get personal information from
- Directly from you
- CCTV footage or other recordings
- Publicly available sources
- Previous employment
- Third parties:
- Where clients use third parties to provide services that are relevant to the products and services we provide (such as support services) those clients may provide third-party details to us.
We keep your information for as long as we are required to legally, such as six years from the end of our last financial year, or three years for payroll records, or a short as required by us to defend legal claims, provide cabling warranties (up to 25 years), or re-contract with former clients who used alternative providers for a period of time (10 years).
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Data processors
IT and Cloud Supplier
This data processor manages our CRM, CPQ and ERP
Payroll and HR Providers
This data processor processes our financial and payroll information
Legal and Professional Services
These data processors provide services such as private healthcare
Others we share personal information with
- Insurance companies, brokers or other intermediaries
- Professional or legal advisors
- Emergency services
- External auditors
- Organisations we’re legally obliged to share personal information with
- Publicly on our website, social media or other marketing and information media
- Professional consultants
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: gdpr@avitagroup.co.uk
Telephone: 020 8663 0077
Post: 1 Clock House Road, Beckenham, Kent, BR3 4JS
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint