We’re Here For You
Complete I.T. Limited
Last Updated: July 2021
Complete I.T. Limited a wholly owned subsidiary company Sharp Business Systems UK Plc
At Complete I.T. Ltd. (“we”, “us”, “CIT”), we take your privacy seriously.
This privacy notice explains how CIT collects and uses personal data, and describes the rights you have with respect to your personal data.
As a responsible organisation, we have implemented numerous technical and organisational measures to ensure the most complete protection of any personal data processed by us, in order to meet the requirements of the General Data Protection Regulation (“GDPR”), and in accordance with any country-specific data protection regulations.
CIT processes personal data for a variety of purposes. We collect this data directly from you, for example, if you engage us to provide services directly to you, or we may also obtain your personal data from publicly available sources (e.g. LinkedIn), or process your data in the context of providing services to your employer (as our customer).
This privacy notice is intended to cover all aspects and scenarios of how CIT processes personal data and it is further supplemented by more specific privacy notices, which are provided to you at the time your personal data is collected, where appropriate.
- Name and Address of the Data Controller
The data controller for the purposes of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Complete I.T. Ltd Oakingham House, Frederick Place, High Wycombe, HP11 1JU
Phone: 01628 243 057
Email: email@example.com (for Data Protection Enquiries)
As a data controller we are responsible for deciding how we hold, use and keep personal data secure. It also means we are responsible for responding to requests you make in relation to how your personal data is used. If you have any questions about the way your personal data is processed, you can contact us on these details:
You may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
- Data Protection Representative
Article 27 of the EU General Data Protection Regulation (GDPR) requires organizations that are not established in the European Union (EU) to designate a representative in the EU if they are subject to the GDPR.
CIT may undertake processing activities to which the GDPR applies. For that reason, CIT has appointed a representative in accordance with the GDPR to act on their behalf if, and when, they undertake data processing activities to which article 3(2) of the GDPR applies. Such appointment is not intended to be an acknowledgement that the GDPR is applicable to any of their processing activities.
The Data Protection Representative of the Controller is:
Sharp Electronics (Europe) Ltd. Sucursal En Espana, incorporated and registered in Spain whose registered office is at Cornellà de Llobregat (08940 – Barcelona), Plaza Pau (Building 6, 4th Floor World Trade)
- Personal data
This privacy notice covers any personal data processed by CIT. “Personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual.
It also includes sensitive personal data (special category data as referenced in the GDPR), including:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Membership of a trade union
- Genetic data
- Biometric data
- Physical or mental health or condition
- Sex life or sexual orientation
Sensitive personal data also includes personal data relating to criminal convictions and offenses.
- What data is processed
We will collect personal data when you set up an account with us, purchase products or services from us, complete forms we provide to you, make a report or notification about our products or services, contact us by phone, email or communicate with us directly in some other way.
Below we define types of personal data processed by us depending on the circumstances in which personal data is collected. We collect the following types of personal data from you:
5.1. Visitors to our website
Personal data we collect about you when you visit our site falls into two categories.
- Information provided directly by you
We collect personal data that you provide voluntarily through our site, for example, when completing online forms to contact us, subscribing to a newsletter, using one of our online, subscribing to receive marketing communications from us, participating in surveys or registering for events that we are organizing. The information we collect about you includes the following:
- Job title, job level or function, role
- Company or organisation
- Company data
- Contact information, including primary email, email address and telephone numbers
- Demographic information, such as industry, country, postcode, preferences and interests
- Other information relevant to client surveys or similar research
- Information pertinent to fulfilling our services to you
- Any other personal data that you voluntarily choose to provide to us
We do not intentionally collect sensitive category data, unless you provide us with such data. While there may be free text boxes on the site where you are able to enter any information, we do not intend to process sensitive information and you should therefore refrain from providing any such data. If you choose to provide any sensitive personal information in this manner, you acknowledge you consent to the collection and processing of this sensitive information.
- Automatically collected information
Our site also uses various social media plugins, please refer to section 4.6 for further information on their use.
When you engage us to provide services to you, we collect and use personal data for valid business purposes in the context of providing services to you. As part of any such service, CIT may also process personal data of individuals who are not directly our clients (for example, employees, customers or suppliers of our clients).
The majority of the personal data we collect and use to provide our services is supplied voluntarily by our clients. Where such data may concern individuals who are not CIT’s direct clients, we obtain a confirmation from our client confirming they have the authority to pass the data to us for lawful onward processing.
We process the following types of personal data:
- Basic information, such as your name, the company you work for, your position and your relationship to a person
- Contact information, such as your postal address, email address and telephone numbers
- Financial information, including any information to facilitate payments between the parties
- Any other personal data relating to you or other third parties which you provide to us for the purpose of receiving our services
We process personal data about our business contacts (e.g. existing, former or prospective customers, including any individuals employed by them and other business contact) in our Client Relationship Management (CRM) systems.
Our CRM systems provide support to the business and facilitate our marketing operations. Sharp uses the information recorded on such systems to share with contacts information about Sharp products, marketing materials, surveys and invitations to events, and for general customer relationship administration purposes.
We process the following categories of personal data in our CRM systems:
- Name, job title, address, email address, phone and fax numbers
- Name of employer or organisation the individual is associated with
- Marketing preferences
- Invitation responses and event attendance confirmations
- Any other information voluntarily provided by in the course of our business relationship
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies), if you attend one of our events. Collection of any such data will be subject to specific privacy notices, relevant to the event your are attending.
We process personal data about participants in events organised by CIT including meetings, conferences, learning sessions and webinars. We may use various applications and online platforms to manage event registration processes. Please take note of their own privacy notices and read them carefully when you provide your personal data for the purposes of event participation.
We process the following categories of personal data (to the extent they apply a specific event):
- Name, age or date of birth
- Client personnel information (home, office and business information)
- Customer information (home, office and business information)
- Email address
- Home or other physical address
- Names of employers
- Role (job title)
- Passport number
We do not intentionally collect sensitive category data, unless you provide us with such data (for example, special dietary requirements which reveal your religious affiliation or any food allergies or other data relating to your health necessary to provide support to participants and facilitate their attendance in CIT
CIT may take photographs and audio or video recordings in public areas of the CIT events. Following the event, recordings may be further edited before they are published or distributed for marketing purposes.
5.5 Individuals who use our platforms and applications
We provide external users, including our clients and their end users, access to various applications managed by us such as our partner portal service or our online training service (Academy). Any personal data collected via these applications (e.g. name, email address, data and time of registration) is captured to provide the individuals with this service, verify their identity and to provide them with a secure log in to a protected web environment. It also enables CIT to provide access or deny access due to misuse of service. Any third party applications provided by CIT are subject to their own privacy notices, please familiarise yourself with their content and read them carefully when you use our platforms and applications.
Social media Channels
CIT uses various social media platforms for recruitment, marketing and business development purposes. We use social media to advertise recruitment opportunities with CIT and to promote products, services and brand related content.
Please note that while CIT is responsible for the content it publishes using social media platforms, CIT will not be responsible for the management and administration of any social media platforms. You should always familiarise yourself and read carefully any legal and privacy terms imposed by these social media platforms. If you have any questions on how the social media platform uses your data, you should contact the platform provider directly.
In some circumstances, CIT may obtained aggregated data from these social media platform providers, e.g. number of “likes” in response to CIT published content and posts, number of visitors who engage with our posts or information on links clicked and downloaded content.
Social media widgets are also implemented on our site e.g. specific button or logo which enables the site to establish a direct connection with the relevant social media platform server. As a result of such direct connection, the social media provider will be informed of the relevant page on our site which triggered such link. If you wish to prevent such sharing, you should review your settings within your social media accounts prior to visiting our website as CIT has no influence on how the data is collected using social media sites.
Our site uses the following social media plugins, widgets:
Our site includes plugins for the social network, Facebook. The Facebook plugins can be recognized by the Facebook logo or by the like button on our sites. For an overview of Facebook plugins, click here.
Our site uses plugins from YouTube, which is operated by Google. If you visit one of our pages featuring a YouTube plugin, it is a connection to the YouTube servers. Here, the YouTube server is informed about which pages you have visited and the videos from CIT You Tube channel that you have watched or engaged with.
If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account. If you are not yet logged in, clicking a YouTube button will show you the YouTube login page for you to enter your login credentials.
- LinkedIn and LinkedIn Lead Gen Forms
- Google Maps
Our site uses the Google Maps map service via an application programming interface (API).
5.7 Individuals who correspond with CIT via email
CIT uses a variety of tools to maintain the security of our IT infrastructure, including our email facilities. Examples of such tools are:
- Systems that scan incoming emails to CIT recipients for suspicious attachments and URLs, in order to prevent malware attacks
- Tools that provide end-point threat detection to detect malicious attacks
- Tools that block certain content or websites
If you correspond via email with a CIT recipient, your emails will be scanned by the tools CIT operates to maintain the security of its IT infrastructure, which could result in content being read by authorised CIT personnel other than the intended recipient.
We process personal data for recruitment purposes, to facilitate the administration of our available employment opportunities and to match your skills, experience and education with specific roles offered by CIT. Any such data may be collected directly from the candidate or from other third parties, about the candidate.
In general terms, we collect the following types of personal data:
- identification documents
- academic records
- work history
- employment information and references.
This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for an interview. CIT will collect further information if you are invited to the interview (or equivalent) stage and onward. Such information includes interview notes, assessment results, feedback and offer details.
As part of our recruitment process, we may also collect special category data from candidates where we have an employment law obligation to do so. This information is relevant to their future working environment at CIT or the future provision of employment benefits, or with the individual’s explicit consent, where collecting such information is permitted by law.
Our recruitment tools and websites contain their own privacy notices explaining why and how personal data is collected and processed by those applications. We encourage individuals using our recruitment tools and websites to refer to the privacy notices available on those tools and websites.
We process personal data about our suppliers (including subcontractors, and individuals associated with our suppliers) in order to manage our relationship and contract, and to receive services from our suppliers.
The personal data we process is generally limited to contact information (name, name of employer, phone, email and other contact details) and financial information, including payment-related information.
5.10 Visitors to CIT offices
When you visit a CIT office, we process your personal data in order to provide you with certain facilities (such as access to our buildings and conference rooms or Wi-Fi), to control access to our buildings, and to protect our offices, personnel, goods and confidential information (for example, by using CCTV).
The personal data we collect is generally limited to your name, contact information, location, and the time you enter and leave our office.
- Visitor records and access badges
We require visitors to our offices to sign in at reception and we keep that record of visitors for a short period of time. Visitors to our offices are provided with a temporary access badge to access our offices. Our visitor records will be used to verify that access badges are returned, to look into a security incident and for emergency purposes (for example, if an office needs to be evacuated).
We monitor and log traffic on our Wi-Fi networks. This allows us to see limited information about a user’s network behaviour, but will also include being able to see at least the source and destination addresses the user is connecting from and to.
CIT uses CCTV monitoring where permitted by law. CCTV images are securely stored and only accessible on a need-to-know basis (for example, to look into an incident).
- Purposes and legal grounds for processing
We limit the collection of personal data to only that which is absolutely necessary to carry out our legal or business obligations. In some cases however the provision of personal data may be partly required by law (e.g. tax regulations), is needed as part of contractual negotiations, or as part of providing a service.
Below, we describe:
- the purposes we collect your personal data for and;
- the legal basis that allows us to process your personal data
|Type of data||Purposes for processing||Legal grounds for processing|
|1.||Visitors to complete-it.co.uk||
|3.||Contacts in our CRM systems||
|4.||Participants in CIT events||
|5.||Individuals who use our platforms and applications||
|6.||Individuals who visit our social media sites, social media plugins and tools||
|7.||Individuals who correspond with CIT via email||
|10.||Visitors to CIT offices||
- How we share your personal data
We share your personal information with the following:
- Our staff: Your personal data will be accessed by our staff but only where this is necessary for their job role.
- Companies in the same group of companies as us: For the purpose of providing a service to you.
- Partners and Dealers: For the purpose of answering queries you have about products and services not directly provided by CIT.
- External service providers: CIT use external service providers to assist with, for example, information technology and other administrative support services. Our service providers are contractually bound to maintain appropriate levels of security and data protection
- Law enforcement and regulatory agencies: if we are required to disclose or share your Personal Data in order to comply with any legal obligation or any regulatory requirement
- Changes of Business Ownership and Control
- Transfers of personal data
CIT as a Sharp group company operate in various locations across the globe. Some parts of our internal infrastructure are centralised which includes provision of information technology services. We may also transfer personal data to third parties (and their affiliates) which provide the above mentioned ancillary services to Sharp group companies.
Therefore, your personal data will sometimes be transferred outside of the jurisdiction in which it was collected and stored. This includes countries outside of the European Economic Area (EEA) and the United Kingdom (UK). Where such a transfer is required, we put in place appropriate security and legal measures to safeguard the safety and security of personal data. CIT as a Sharp group company has implemented appropriate intragroup data transfer agreements, providing for a legally binding and enforceable commitment to protect any personal data within the Sharp company group. Where personal data is transferred to a third party service provider, we also ensure legally binding contractual protections are in place, consistent with the GDPR and any other applicable data protection laws.
- Your rights
You have the following rights in relation to your personal data:
- To access the personal data held by CIT about you
- To have your personal data corrected, for example, if it is incomplete or incorrect
- To opt out of receiving marketing communications at any time
- To restrict or object to the processing of personal data or request erasing personal data (in certain circumstances and subject to applicable law)
- To receive a copy of the personal data which you have provided to CIT, in a structured, commonly used and machine-readable format (known as “data portability”), subject to applicable laws
- Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent
- The right to complain to a data protection authority
To exercise your rights to any of the above or to lodge a complaint about an alleged breach of data protection law, please contact us via firstname.lastname@example.org
CIT has implemented appropriate organisational and technical controls to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.
- Updates to this Policy
We recommend that you check for updates to this notice from time to time but we will notify you directly about changes to this notice or the way we use your personal data when we are legally required to do so.