Legal Privacy Notice

Last Updated: 01/07/2018

Contents

  1. About us
  2. What personal data do we collect?
  3. How do we collect your personal data?
  4. Who will we share your personal with?
  5. Access and changes to your personal data
  6. Managing your contact with KCOM
  7. How long do we hold on to your personal data?
  8. Changes to this policy
  9. Enquiries and complaints
  10. Visitors to our website
  11. Users of products or services
  12. If you contact us or we contact you
  13. If you apply for a job with us or are an employee or have worked with us in the past
  14. Marketing

 

 

1. About us

Welcome to our Privacy Notice!

This Privacy Notice is published by KCOM Group PLC, a company registered in England and Wales under number 2150618 ("KCOM" or "we" or "us") and has been published to that you are aware of how and why we collect and process your personal data.  

Our details are as follows:

  • Legal Entity: KCOM Group plc
  • Information Commissioners Office Registration Number: Z5732459
  • Data Protection Officer: Company Secretary
  • Email address: dpo@kcom.com
  • Postal Address: 37 Carr Lane, Hull, East Yorkshire HU1 3RE

Any reference to you or yours means is a reference to any user of this site, of our services or any person who supplies us with information.

By using our website or taking any of our services you agree to the use of your personal information as set out in this Privacy Notice.

 


 

2. What personal data do we collect?

KCOM takes privacy seriously. The personal data we collect, the way in which we will collect it and how we use that personal data will depend on the reason for which we have gathered it in the first place.

This Privacy Notice explains what personal data we collect, how we will collect it and how we use your personal data:

By using our website or taking any of our services you agree to the use of your personal information as set out in this Privacy Notice.

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3. How do we collect your personal data?

We may collect information about you:

  • Directly: This information will be gathered from a direct interaction with you by:
    • You corresponding with us by post, email, phone, through social media or through the ‘contact us’ or Livechat functionality on our website
    • An application for our products or services or a request for more information
    • Your creation of an account on our website
    • A request for more information about the company to be sent to you (for example a request for a copy of our annual report and accounts)
    • A request for marketing to be sent to you
    • Your completion of a survey
    • You entering into a competition or promotion
  • Automatically: Some personal data is collected automatically when you visit our website. This is described in more detail in the ‘Visitors to Our Website’ section of this Privacy Notice
  • From third parties or where the information is publicly available: This information is gathered by us from a third party or a publicly available source, including:
    • Analytics providers such as Google
    • Networking sites such as Linkedin
    • Buying in data for marketing purposes

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4. How will we use your personal data and who will we share your personal data with

How we use your personal data and who we will share it with will depend on the reason for us obtaining the data and is described in more detail within this Privacy Notice.

We will only use your personal data with your consent, where:

  • We are looking to enter into a contract with you or to perform our obligations under the contract
  • We are complying with a legal obligation
  • To protect your vital interest
  • To pursue one of our legitimate interests

We have to share your personal data with:

  • Other companies within our group
  • By third parties who provide us with services to enable us to deliver the services we offer
  • Our professional advisors or by third parties who provide us with services which we use internally to administer our services
  • Regulators and other authorities for the purposes of prevention, detection and prosecution of criminal offences or issues relating to national security or, where we are required to do so in the event of a national emergency to comply with other legal or regulatory requirements; as identified within this Privacy Notice or within our contract with you

Some external third parties (for example our suppliers) are based or have offices outside the European Economic Area (‘EEA’) and if they process of your data as part of our relationship with them it may mean that your personal data is transferred outside the EEA. Where this occurs we will ensure that an adequate level of protection is applied in accordance with the Data Protection Laws

Personal data will not be sold or transferred to third parties other than:

  • As identified in this Privacy Notice
  • In accordance with our Terms and Conditions or the terms of any other contract we have in place with you
  • Where you consent to us doing so
  • To comply with lawful requests made by a regulator or other authority

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5. Access and changes to your personal data

You have a number of rights relating to your personal information, including:

  • The right to request a copy of the personal information we hold
  • The right to ask us to correct any inaccurate information
  • The right to ask us to delete any information if we have no lawful reason to process such data
  • The right to request your personal information be transferred to another person or company
  • The right to object to us contacting you for marketing

More information on this can be found at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/.

If you wish to exercise any of your rights relating to your data (including requesting a copy of the personal data which we hold about you) please contact us in writing at the address given at the start of this Notice or by using our Data Request Portal.

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6. Managing your contact with KCOM

If you have any queries relating to this Notice or our processing of your personal data then please:

  • Email us at dpo@kcom.com
  • Write to us at the address given above, or
  • Phone the relevant number:
    • Hull and East Yorkshire business and residential customers please call 01482 602555
    • National businesses please call 0800 138 48 58 (Option 5) or contact your Service Manager

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7. How long do we hold on to your personal data?

We will only use your personal data for as long as we require it to fulfil the purpose which we have collected it for plus any additional period we are required to keep the data for due to legal, accounting and reporting obligations.

In determining how long we can retain the personal data for we will take account of:

  • The amount of personal data
  • The nature and sensitivity of the personal data
  • The harm which would result from unauthorised use or disclosure
  • Whether we can achieve our purpose without using the personal data, and
  • Whether we are required to keep the personal data for legal, accounting or reporting obligations

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8. Changes to this policy

We may keep this Privacy Notice under review and may make changes from time to time which we will publish on the website. This Privacy Notice was last updated on May 1 2018.

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9. Enquiries and complaints

If you have any further enquiries or concerns about our Privacy Notice please email us at dpo@kcom.com or write to us at the address given at the start of this Privacy Notice.

We will always try to resolve any enquiries or complaints or requests made in relation to your personal data to the best of our ability but you have the right to complain at any time to:

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 01625 545700
Fax: 01625 524510
Website: www.ico.org.uk

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10. Visitors to our website

When you visit any of our websites you can browse without giving us any personal information, however we will use various third party tools (as identified below) to collect behaviour-based data around your use of our website. The type of data we collect includes:

  • The number of visitors
  • What pages are viewed, and
  • How long is spent looking at our website

Any data collected by the third party tools will not processed by us, nor will we make any attempt to use this information in order to identify individual visitors to our websites.

Like many other websites, we may use a standard technology called a "cookie". Cookies collect information about your use of our website to enable you to navigate between pages efficiently, remember your preferences, and to improve user experience. Our website will use the information collected by cookies to show you relevant adverts. You can find out more information about cookies and the cookies we use on our websites by using the link below:

kcom.com – Cookie policy

business.kcom.com – Cookie policy

heybusiness.kcom.com – Cookie policy

kcomhome.com – Cookie policy

kcomplc.com – Cookie policy

kcomcareers.com – Click here

 

Online tools

We have various tools on our websites that are used to help you to manage your relationship with us:

  • You can sign up to our account management tools which will capture your personal information on entry, more details are provided here
  • You can register your interest in any of our products and services by providing your details to us through our website:
    • If you are a Hull and East Yorkshire residential customer, we will ask for your address, email address, name, date of birth, contact number and we will ask you to answer a security question. We will use this information to register you on our systems and create an online account to enable us to contact you, which we will do in line with your stated preferences
    • If you are a business customer we will ask you for your company name, a contact name, email address, phone number and will use this information and will use this information to contact you in relation to your enquiry
  • You can manage your marketing preferences through our online tool here

 

Third parties

We will share the personal data we collect on the website with the following third parties as described in the following Privacy Notices:

 

Third Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for them. When you leave our website, we encourage you to read the Privacy Notice of those websites you visit.

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11. Users of products or services

What personal information do we collect?

Where you take services from us we will collect from you the following personal information, this can be provided to us to through our customer service team, through the website or through one of our account management tools:

Residential consumer

  • Categories of personal data collected – Name, Address, Contact number, Email address, Payment details in order for us to process payment for the services through your chosen method, Information required for security clearance / confirmation of identity

Business customer

  • Categories of personal data collected – Contact name, Email address

In addition to the above we will automatically gather the following information to enable us to deliver the services:

  • Where you take internet services we will look at the amount of time you spend online, and what time you are using the services and what websites you visit in order to help us manage the network
  • Where you take telephony services we will hold information about calls you have made including the number you have called and the length of the call to enable us to accurately bill you

 

How we use your personal data

We will allocate and store a unique identifier if you take services from us and may also gather information from you to enable us to confirm your identity when you contact us in the future to discuss your account.

We have various tools available which enable you to manage your account. Where you use one of these we will use the personal data you have provided to enable you to use the relevant online account management tool. You do not have to provide us with this information, but you will not be able to use the online tool if you fail to do so.

In the event you do not pay any amounts owing to us we may transfer the debt onto Creditstyle, a third party who will recover the monies owed on our behalf. Further information is shown below.

In addition to this, we may use the information we hold to enable us to carry out internal investigations where we suspect fraud or criminal activity.

 

Marketing

We may also use your personal information to keep you up to date with news about KCOM and any products and services or information which we think you may find of interest, but only where you are happy for us to do so (more information can be found here). If your preference is that we do not contact you for the purpose of direct marketing, we will continue to use the data we hold to provide you with service updates.

If we use your personal information for any other purpose, then this will be set out in the contract we have in place with you for services.

Insight

We are always looking to drive improvements to our services and customer experience. To enable us to do this, we may:

  • Use your personal data to invite you to participate in surveys or other feedback activities
  • Use anonymised customer data to look at patterns in order to proactively identify those improvements.

Third parties

In order to provide you with the services, we may share your details with our third party suppliers as detailed in our contract with you or as set out below. Where this is the case we will share only the information required to enable the provision of the services and we will not pass on your information for marketing purposes.

Residential consumers

  • Name of 3rd party – Lightsource Design Limited
  • Services provided by 3rd party – Engineering services
  • Personal data shared – Name, Address, Telephone number, Email address

Residential consumers

  • Name of 3rd party – Cumberland Comms Limited
  • Services provided by 3rd party – Engineering services
  • Personal data shared – Name, Address, Telephone number

Residential consumers

  • Name of 3rd party – North Midland Construction Limited
  • Services provided by 3rd party – Engineering services
  • Personal data shared – Name, Address
  • Privacy Notice

Residential Customer outside Hull and East Yorkshire

  • Name of 3rd party – Talk Talk
  • Services provided by 3rd party – Supplier of telephony and internet services
  • Personal data shared – Name, Address
  • Privacy Notice

Business Customer outside Hull and East Yorkshire Area

  • Name of 3rd party – BT
  • Services provided by 3rd party – Supplier of services
  • Personal data shared – Name, Address
  • Privacy Notice

Consumer Mobile Services

  • Name of 3rd party – Abzorb Systems Limited
  • Services provided by 3rd party – Supplier of mobile services
  • Personal data shared – Name, Address, Mobile Number
  • Privacy Notice

All customers

  • Name of 3rd party – Creditstyle
  • Services provided by 3rd party – Debt collection
  • Personal data shared – Name, Date of birth, Address, Phone number, Mobile number, Email address and list of transactions for which we are owed payment
  • Privacy Notice

Residential consumers

  • Name of 3rd party – Dun and Bradstreet
  • Services provided by 3rd party – Credit reference agency
  • Personal data shared – Name, Date of birth, Addresses over the last three years
  • Privacy Notice

 

Special categories of data

There may be circumstances when we are required to gather information regarding your health to enable us to deliver service to you in the best and most efficient way (for example our engineers may need to know if you have a disability when making a home visit or our customer service team may need to know if you are registered blind to ensure your bill is provided in Braille). We will only process this data with your consent and will do so with extra care and always in accordance with this Privacy Notice. Information regarding your health will not be shared with third parties without your consent.

 

Credit checks

For residential consumers:

Where you wish to take services from us we will conduct a credit check. Where you are a residential customer we will ask you for your name, date of birth and your addresses over the last three years and this information will be checked against our internal records. Where we are concerned about the results of this check we may carry out a further check with Dun&Bradstreet Ltd.

For business customers:

 

Directory services

  • Where you take residential telephone services from us, we will include your name, address and phone number in our ‘White Pages’ telephone directory unless you request to be ‘ex-directory’ in accordance with our terms and conditions
  • Where you take telephone services on behalf of a business in the Hull and East Yorkshire area we will include the name of your business, a contact name (where requested), business address and phone number in our ‘Colour Pages’ telephone directory unless you request to be ‘Ex-directory’. Our Colour Pages website is designed and managed by Agile Spice Limited
  • Where you choose to take an advert in our telephone directory we will use your details to contact you in order to clarify queries with respect to the advert and to discuss renewal of the advert

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12. If you contact us or we contact you

What personal information do we collect

The information we collect and process will be that you provide us directly and any information we require to enable us to deal with your query. The nature of the information we gather will depend on your enquiry and the method you use to contact us, but is likely to include your name, email address, address and/or telephone number. We will not request or collect any information which is not required. We will collect this information through the medium you use to make contact with us, whether this is over the phone, by email, in writing, through social media or through our website. 

If we cannot respond to your enquiry immediately and you are not a customer of KCOM we will prepare a file relating to your enquiry which will only be accessed by those of our employees who are involved in resolving your enquiry. If you are a customer we will note your enquiry against your account.

If you contact us by phone we will record your call and hold this recording for 30 days. This recording will be used to enable us to assess quality control and provide training to our employees.

 

If you contact us by email

We will collect and hold your email address together with any other personal information you send to us as part of your email. If you use the ‘email us’ function on www.kcomhome.com we will ask existing customers for their name, address, email address and contact number to enable us to find your account and contact you to deal with your enquiry. If you use the ‘contact us’ functionality from any of our other websites will ask you for your name, postcode, email address and contact number and where appropriate details of your business.

 

If you visit our shop or premises

CCTV is in operation at our shops and on our premises, but will only be accessed as required for security reasons.

 

Competitions

We occasionally run competitions. When you enter a competition we will ask you for various information, this is likely to include your name, address and telephone number. Where you are happy for us to do so we will use this information to inform you of products and services which we believe may be of interest. Click here to find out more.

 

Third parties:

If we collect your data using the methods identified below we will use a third party to manage our interaction:

Social media

LiveChat

Completion of a survey

Depending on the nature of your enquiry we may have to share your personal information with our insurance brokers Willis Towers Watson whose privacy policy can be viewed here or other advisers appointed on behalf of KCOM.

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13. If you apply for a job with us or are an employee or have worked with us in the past

If you apply for a job with us we will hold all the information you provide us with as part of the application for the purposes of progressing your application and to assess your suitability for the role for which you have applied.

 

Applying for a job with us

Applying for a job with KCOM is usually managed through either:

  • Our online application system, or
  • A recruitment agent appointed on behalf of KCOM

 

Online application system:

Our online application system is provided by eArcu, who will collect and process your personal data on our behalf. If you send us a speculative CV we may use the contact details you provide to contact you and where there is a position available which we believe you are suitable for we will ask you to submit your application through the eArcu system.

When applying for a position with  us using eArcu you will be asked to provide us with the following information:

  • Name
  • Postcode and town
  • Email address
  • Mobile number
  • Salary expectations
  • Notice requirements
  • Copy of your current CV

You do not have to provide us with this information but failure to do so may affect your application.

 

Recruitment agents:

We may advertise positions through recruitment agents who will gather information with respect to potential employees on our behalf and will share this with us. We  have relationships with a number of recruitment agents to cover the various different disciplines which we may recruit into.

 

Progressing an application

Once you have submitted your application we will share your information with those people within KCOM who will be involved in the recruitment, this will be our human resources team and those employees of KCOM who are directly involved in the recruitment with whom the vacancy sits.

We will use the contact details you provide to contact you to inform you of the outcome of your application.

If you are invited to attend an interview at our offices your details will be recorded in our visitors log for security purposes and you should be aware that CCTV is in operation on our sites.

Your details will be archived on the eArcu system after 600 days of inactivity and will be permanently deleted after a further 90 days.

 

Making an offer of employment

If you accept an offer of employment:

  • as an employee of KCOM your personal information will be loaded onto our record management system CIPHR
  • We use Agenda Screening Services to carry out security checks, their privacy policy can be viewed here. We will use your name and email address to set you up on Agenda’s system and you will be sent a link to their screening system where you will be asked to input further information.  Some roles within KCOM require us to obtain enhanced security clearance, where this is the case we will inform you of this and request the additional information we require

 

Leaving your employment with KCOM

If you leave your employment your details will remain on CIPHR for six years.

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14. Marketing

Where you are happy for us to do so we may use your personal information to provide you with details of products, services or special offers which we believe may be of interest to you by post, email, text message or over the phone. If you do not want to receive any marketing information you can:

  • Click the ‘opt out’ button on at the bottom of any marketing email or send an email to dpo@kcom.com
  • Respond to a marketing text message with the word ‘KCOM UNSUBSCRIBE’
  • Write to the Data Protection Officer at the address given above, or
  • Inform us over the phone following a marketing call or by phoning the relevant number:
    • Hull and East Yorkshire business and residential customers please call 01482 602555
    • National businesses please call 0800 138 48 58 (Option 5) or contact your Service Manager
  • Where you are a residential customer, manage your preferences through My Account
  • Alternatively, where you are a business customer, manage your preferences through our Preference Centre for Businesses

Please note where you have residential consumer services and business services and you wish to stop receiving marketing from KCOM which relates to both of these relationships we will require you to opt out of marketing for each stream separately.

Where you elect not to receive marketing information (whether this is all marketing or only marketing in relation to some areas) we would ask that you note the following:

  • Please allow 28 days for the relevant marketing communications to stop completely
  • We will continue hold your name, address, phone number and email address on our marketing database but will only process this information as necessary to ensure that we do not market to you directly in the future
  • Where you use the ‘opt out’ link contained at the bottom of a direct marketing email we will stop sending marketing emails to this email address only, if you have any other email addresses registered with us and wish us to stop sending marketing emails to these addresses as well please ensure that we are provided with the relevant details to enable us to update our records
  • This opt out relates to direct marketing only (i.e. marketing which uses your personal data), this will not stop marketing which is not targeted at you personally (for example a mail shot addressed ‘To the Occupier’ where the occupier is not a customer of KCOM)

We use third parties to help us manage our marketing database and marketing campaigns and so will share your personal information with them. These companies are:

  • Marketo Incorporated
  • Salesforce (EMEA Limited)
  • Dotmailer Limited

 

Digital marketing adverts

On occasion, we may carry out online marketing via third party tools that use either anonymous IP addresses or email addresses to display digital adverts to you across other websites or on social media via cookies:

  • Remarketing via website URL: If you have visited certain, specific pages on any of our websites
  • Personal data: If you have provided your email address for marketing purposes
  • Behavioural: We may run adverts through search or display networks (e.g. Google Display Network) that serve our ads to audiences in pre-defined categories

If you no longer wish to see a digital advert from  us, please clear your cookie settings and remove email permissions. In all scenarios, you can tailor your browsing experience for all of your online activity by modifying your browser settings: http://www.youronlinechoices.com/uk/five-top-tips

We will not share your information with any unaffiliated third parties for the purposes of enabling them to market their products or services to you.

Where you request not to receive marketing information from us we will still need to use your personal information to send you service updates.

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