The purpose of this privacy statement is to explain how Sabre MS processes all personal data to fulfil its data protection responsibilities. This statement will be supplemented by ‘specific to client’ privacy notices when needed.
The scope of this statement covers all related activities by the staff and associates/ consultants of Sabre MS referred to as SMS for the remainder of this privacy statement.
The role of SMS in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the SMS privacy officer (PO), supported by an external DPO, to ensure that it is processed in accordance with the latest UK data protection legislation. The PO & the DPO can be contacted by email using firstname.lastname@example.org
The sort of personal data processed by SMS will only be basic contact information for the purposes of networking, business development, preparing contracts and setting up invoices. Banking details will also be collected for the purpose of paying creditors.
SMS’ duty of confidentiality means that SMS staff will treat your personal data with due respect and in confidence. It is only disclosed to those that need to know it. SMS expects the same duty of confidentiality of all third parties with whom it shares your personal data.
Ordinarily SMS does not process your personal data outside the UK but when necessary, will take the appropriate measures to ensure it is done lawfully and securely.
SMS will always process personal data lawfully and in such instances as described below:
In all cases the processing of personal data by SMS shall be:
SMS will share personal data, but only when absolutely necessary, with some or all of the following third parties:
SMS uses reasonable organisational and technical measures to ensure personal data is kept secure in line with its internal information security policies. For instance, SMS uses encryption to safeguard data when appropriate. Other than mobile phone contact data, all personal data in automated form is processed and backed up using an HM Government accredited supplier. Further details can be found under the ‘SERVER SECURITY’ section on the homepage of our website.
SMS follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:
At the end of the retention schedule SMS will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that SMS allows up to 3 months after the retention schedule to complete the action.
SMS websites may link to appropriate websites for your interest. If these are used, the visitor should be aware that the SMS has no responsibility for the control, content or handling of personal data by these other websites.
The UK General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:
Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.
Raising concerns, exercising rights or making queries about SMS’ processing of personal data can be done by contacting the SMS privacy officer/ DPO. Please be aware that SMS will need to determine your identity before responding fully, therefore, you may be asked for proof of ID or other material that, in context, will enable SMS to confirm your identity. Alternatively, you may wish to contact the ICO directly, using the details provided above.