ABOUT USPersonalalarms.com are the online retail division of JNE Security Ltd.We offer the widest range of low cost security products in the UK and specialise in most electronic security alarms and devices.
Due to our affiliation with JNE Security Ltd we are able to offer an extensive range of Crime Prevention Products at prices significantly lower than most retail shops and websites. JNE Security were one of the first companies in the UK to develop the Electronic Personal Alarm and recently have become the only Company to receive Sold Secure and Secured by Design Approval for Personal Alarms. As an innovator of Security Products they continue to pioneer new ideas to combat crimes such as Distraction Burglary, Bogus Callers, Fraud Detection, Rape and Domestic Violence.
Personalalarms.com pride themselves on quality and service. All of our products come with at least a 12 month guarantee and we endeavour to ship most orders within 48 hours of purchase. We regularly have special offers and are constantly sourcing new products to combat a variety of crimes.  
WEEE RegulationsJNE Security Ltd producers registration number WEE/GE1473RT In recent years the amount of Waste Electrical and Electronic Equipment (WEEE) being sent to landfill has increased dramatically. To arrest this trend legislation was brought into force that aims to decrease the amount of WEEE going to landfill and increase the amount being recycled. The EU WEEE Directive 2002/96/EC requires that producers of electronic equipment be responsible for the end of life collection, treatment, recovery and environmentally sound disposal of electrical and electronic equipment (EEE) put on the EU market after 13th August 2005. The Directive was transposed into UK law at the start of 2007 and as a producer JNE Security Ltd endeavours to meet these environmental responsibilities for managing WEEE. JNE Security Ltd has registered with Budget Pack compliance scheme as a producer of electrical and electronic equipment. More information can be found at www.budget-pack.com All electronic products sold by JNE Security Ltd are marked with a crossed out wheelie bin symbol to show that they should not be disposed of with normal waste. The Budget Pack compliance scheme is approved by the UK Environmental Agency under registration number WEE/UP3838PL/SCH for both household and non household equipment. Any products purchased from JNE Security Ltd at the end of the shelf life can be returned for environmentally safe disposal.
JNE SECURITY LTD – PRIVACY POLICY
Contents
1 INTRODUCTION
2 PRIVACY AND PERSONAL DATA PROTECTION POLICY
2.1 THE GENERAL DATA PROTECTION REGULATION
2.2 DEFINITIONS
2.3 PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA
2.4 RIGHTS OF THE INDIVIDUAL
2.5 LAWFULNESS OF PROCESSING
2.5.1 Consent
2.5.2 Performance of a Contract
2.5.3 Legal Obligation
2.5.4 Vital Interests of the Data Subject
2.5.5 Task Carried Out in the Public Interest
2.5.6 Legitimate Interests
2.6 PRIVACY BY DESIGN
2.7 CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA
2.8 INTERNATIONAL TRANSFERS OF PERSONAL DATA
2.9 DATA PROTECTION OFFICER
2.10 BREACH NOTIFICATION
2.11ADDRESSING COMPLIANCE TO THE GDPR
List of Tables
TABLE 1 – TIMESCALES FOR DATA SUBJECT REQUESTS
Introduction
In its everyday business operations JNE SECURITY LIMITED makes use of a variety of data about identifiable individuals, including data about:
Current, past and prospective employees
Customers
Users of its websites
Subscribers
Other stakeholders
In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.
The purpose of this policy is to set out the relevant legislation and to describe the steps JNE Security is taking to ensure that it complies with it.
This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to JNE Security systems.
Privacy and Personal Data Protection Policy
2.1 The General Data Protection Regulation
The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that JNE Security carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is JNE Security s’ policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.
2.2 Definitions
There are a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:
Personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘processing’ means:
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘controller’ means:
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
2.3 Principles Relating to Processing of Personal Data
There are a number of fundamental principles upon which the GDPR is based.
These are as follows:
Personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
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 (‘purpose limitation’);
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
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’);
kept in a form which permits 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 in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject
(‘storage limitation’);
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’).
The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
JNE Security will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
2.4 Rights of the Individual
The data subject also has rights under the GDPR. These consist of:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.
Each of these rights are supported by appropriate procedures within JNE Security that allow the required action to be taken within the timescales stated in the GDPR.
These timescales are shown in Table 1.
Data Subject Request Timescale
The right to be informed When data is collected (if supplied by data subject)
or within one month
(if not supplied by data subject)
The right of access One month
The right to rectification One month
The right to erasure Without undue delay
The right to restrict processing Without undue delay
The right to data portability One month
The right to object On receipt of objection
Rights in relation to automated decision making and profiling. Not specified
Table 1 – Timescales for data subject requests
2.5 Lawfulness of Processing
There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is JNE Security policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.
2.5.1 Consent
Unless it is necessary for a reason allowable in the GDPR, JNE Security will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.
If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.
2.5.2 Performance of a Contract
Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.
2.5.3 Legal Obligation
If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.
2.5.4 Vital Interests of the Data Subject
In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. JNE Security will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.
2.5.5 Task Carried Out in the Public Interest
Where JNE Security needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.
2.5.6 Legitimate Interests
If the processing of specific personal data is in the legitimate interests of JNE SECURITY LIMITED and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.
2.6 Privacy by Design
JNE Security has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.
The data protection impact assessment will include:
Consideration of how personal data will be processed and for what purposes
Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
Assessment of the risks to individuals in processing the personal data
What controls are necessary to address the identified risks and demonstrate compliance with legislation
Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.
2.7 Contracts Involving the Processing of Personal Data
JNE Security will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR. For more information, please contact the DPO Team.
2.8 International Transfers of Personal Data
Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.
2.9 Data Protection Officer
A defined role of Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.
The Data Protection Officer can be contacted by emailing sales@jnesecurity.co.uk
2.10 Breach Notification
It is JNE Security policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.
The following actions are undertaken to ensure that JNE Security complies at all times with the accountability principle of the GDPR:
The legal basis for processing personal data is clear and unambiguous
A Data Protection Officer is appointed with specific responsibility for data protection in the organisation (if required)
All staff involved in handling personal data understand their responsibilities for following good data protection practice
Training in data protection has been provided to all staff
Rules regarding consent are followed
Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
Regular reviews of procedures involving personal data are carried out
Privacy by design is adopted for all new or changed systems and processes
The following documentation of processing activities is recorded:
Organisation name and relevant details
These actions are reviewed on a regular basis as part of the management process concerned with data protection.
Relevant technical and organisational controls in place
Personal data retention schedules
Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
Categories of individuals and personal data processed
Categories of personal data recipients
Purposes of the personal data processing
These actions are reviewed on a regular basis as part of the management process concerned with data protection. |
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