Smart Manufacturing Technology Privacy Notice

Published 12th August 2024

Contact Details

Contact: Information Security Manager

Address: 1 Clifton Lane, Wilford, Nottingham, NG11 7AT

Introduction

We are Smart Manufacturing Technology (SMT), a globally integrated leader in mechanical transmission engineering services and software development. Our Head Office is in Nottingham, England. We are registered as a data processor with the Information Commissioners Office (ICO).

This Privacy Notice applies to our processing of personal data collected and processed relating to the use of our website, the assessment and recruitment of candidates, the employment of staff, engagement of contractors and subcontractors, through business relationships and customer service, and through other engagements with businesses, regulators or other third parties.

Your privacy, and the security of your information is a responsibility that SMT takes seriously. We understand our responsibility to ensure that any personal data that we collect, store, use or otherwise handle, is processed in accordance with applicable data protection legislation.

The type of personal data we collect

At SMT we only collect the personal data necessary to provide our services, or to undertake necessary internal business functions such as recruitment or human resources management.

We need to keep records of engagements with our business and website, as well as basic contact details to inform our interactions with customers, candidates, and service partners.

The personal data that we collect includes

(Note this list is non-exhaustive and is provided only for example)

names and signatures,
addresses including email, physical, and internet protocol addresses.
telephone numbers,
date of birth,
bank account details and other necessary payroll information,
Photographs and filmed footage, including CCTV footage
right to work and ID documentation,
gender, race, and religious information.
work and education histories including personal and employment references.
medical information including sick notes and vaccination status (for business travel)
Driver’s license and other drivers’ eligibility related information.
other personal identifiers such as location data on a mobile phone or the advertising ID of a device, or a cookie ID.

This list is non-exhaustive, and we may, where deemed necessary and appropriate to our relationship, collect further personal data from you, people you know, or third parties that you identify to us.

How we get the personal data and why we have it

Most of the personal data that we process is provided to us directly by you and relates to your use of our website, your employment or employment application, or the provision of business services by, or to, SMT.

We also receive personal data indirectly, from the following sources in the following scenarios:

Recruitment agencies – relating to employment opportunities.

Universities – relating to employment opportunities and research projects.

Referring partners – where you partner with companies to refer your details to us for services, employment, or other business or research opportunities.

Your employer(s) – in the case or references, or service introductions and referrals.

Education providers, accreditation, and qualification bodies – in the case of references, training and development opportunities and applications for funding relating to training and development opportunities.

We use the information that you have given us to provide our services, these services fall across three broad categories:

Fulfilment of customer facing (B2B) business services and commercial relationships
Fulfilment of research and development projects and other innovation focussed collaborations
Fulfilment of internal business processes and administration

We use the information to understand your needs and provide you with a better service, to fulfil our business interests, legal, regulatory and contractual requirements and for the following reasons:

Internal record keeping
We may use the information to improve our products and services.
We may use the information to assess your suitability for employment or promotion.
We may periodically send promotional emails about new products, product updates, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes.

We also employ Google Analytics to process information on visitors to our website, this helps us to monitor and improve the way in which people interact with our website for example which pages are of particular interest and which browsers are most widely used. The cookies collect information in an anonymous form.

Google Analytics uses cookies. These are small text files that are placed on your computer. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

Please see the Google Analytics website for further information. This can be found at www.google.com/analytics

To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout

Where necessary and appropriate, we may share this information with:

Third parties providing HR, Health & Safety or Quality Management services to us (e.g.: banks, accountants, outsourced payroll, pension providers, HRIS provider, employee benefits providers, outsourced health & safety consultancy, outsourced staffing and recruitment services, or outsourced quality management consultancy).

Third parties providing IT and information security related services (e.g.: Microsoft or AWS for virtual infrastructure services, or our outsourced major incident response provider).

Third parties providing sales and marketing services (e.g.: we use third parties such as Dynamic CRM, Zendesk, Eventbrite and Mailchimp to manage customer relationships, and for business development purposes). Measures are in place to afford the transferred information an adequate level of protection.

Third parties providing professional and/or insurance services (e.g.: health or vehicle insurance providers, auditors, and certification bodies).

Legal and regulatory authorities (e.g.: we may be obligated to disclose personal data to law enforcement, tax authorities, courts, or other regulatory authorities).

Parties involved in the acquisition or transfer of SMT’s assets, such as a prospective buyer, or their agents.

When sharing your personal data, we me have need to transfer it outside of the country of collection, this may mean transferring the information outside of the UK, or outside of the EEA, this may be to third countries, or to countries with no adequacy agreement in place. In such circumstances we will only do so in a manner compliant with the applicable data protection legislation, ensuring that appropriate security measures are in place to afford the transferred information an adequate level of protection.

The lawful bases we rely on for processing personal data are:

(a) Your consent.
You can remove your consent at any time by contacting privacy@smartmt.com

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a legitimate interest.

(e) We have a vital interest.

It is unlikely that SMT will rely on the lawful basis relating to vital interests to process your personal data. SMT only relies on vital interest as a lawful basis where the sharing of information is necessary to protect someone’s life, or to avoid significant harm to life, in an emergency.

SMT does not rely on the lawful basis relating to public tasks as we do not process personal data in the exercise of official authority or to perform public interest tasks set out in law.

Opting Out

You may choose to restrict the collection or use of your personal information in the following ways:

To opt out of any email communications from us, please click the ‘unsubscribe’ link at the foot of the email in question. If no ‘unsubscribe’ link is present, please respond to the email stating your wish to unsubscribe.
If you have previously agreed to us holding or using your personal information, you may change your mind at any time by emailing us at privacy@smartmt.com
If you wish to opt out from any cookies being stored on your browser, please navigate to your internet browser’s settings and alter them accordingly.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

How we store your personal data

Information is stored securely, SMT employs technical and organisational security measures, including strong encryption to protect your personal data.

Paper and electronic records shall be retained for the following periods at the end of which they are securely disposed of, or put beyond use:

Customer records – 10 years after ceasing to be a client / customer.
All HR records (candidates, employees & contractors) – Held in line with the statutory and non-statutory retention periods listed on the CIPD website: https://www.cipd.org/uk/knowledge/factsheets/keeping-records-factsheet.
Financial documents, timesheets, and attendance records – 6 years from the end of the current financial year in line with the HMRC records retention guidance.
Insurance records – 40 years from the date the document or electronic record was created.
Photographs and filmed footage, including CCTV footage – kept for 30 days unless they are required for a criminal investigation as outlined in the retention schedule.
All paper records containing personal data are disposed of by secure information disposal methods in line with applicable standards and regulations.
All data storage media (hard drives / pen drives / DVD etc.) are wiped and factory reset prior to internal reuse of any associated device and are wiped to NIST / NCSC industry standards, or permanently destroyed, prior to external recycling or sale of any associated device.
Archived records clearly display the scheduled destruction date.

Links to other websites

Our website or communications that you may receive from us may contain links to enable you to visit other websites of interest more easily. If you click on links to websites other than www.smartmt.com, you should note that we do not have any control over these other sites. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and are not governed by this privacy notice. We accept no responsibility or liability for such other websites. You should exercise caution when entering personal information online and look at the privacy statement applicable to the website in question.

Data subject rights

Under data protection law, data subjects have rights including:

Your right of access – You have the right to ask us for copies of your personal data.

Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Please note that the rights available to you are subject to the lawful basis for processing your data, for example if you have provided your consent, you cannot object to that consent, however, you do have a right to withdraw consent.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at privacy@smartmt.com if you wish to exercise your data subject rights.

Changes to this notice

Smart Manufacturing Technology Limited’s privacy notice is subject to change at any time. Smart Manufacturing Technology will ensure the most recent notice is always available on our website.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us at:

Privacy Team, Smart Manufacturing Technology Ltd
1 Clifton Lane, Wilford
Nottingham, NG11 7AT
E: privacy@smartmt.com

SMT take your privacy seriously and invite you to raise any concerns to us directly in the first instance, to allow us the opportunity to advise, and where necessary, perform any relevant investigations.

You have the right to complain directly to the ICO if you have concerns with how we are processing your personal data.

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk