Identity and Contact Details
Midlands Surface Analysis (MSA) Ltd was founded in 2011 by John Sullivan and Sayah Saied to create a contract analysis service able to apply surface chemical analysis techniques to the widest range of technological problems.
Midlands Surface Analysis Ltd, Registered Address First Floor Copthall House,1 New Road, Stourbridge, West Midlands, DY8 1PH Trading Address: Midlands Surface Analysis Ltd, Room N619, Aston University, Birmingham B4 7ET, UK. Company Registration Number: 7464766. Assigned Representative: John Sullivan: Telephone: 0121 204 3532; E-mail Address: email@example.com
Data Protection Fee: We are a micro-business that does not process large amounts of personal data, with no CCTV usage. We have reviewed the personal data we hold and believe that we are exempt from paying the fee because we are only processing personal data for core business purposes, including,
- advertising, marketing and public relations,
- accounts and records,
all of which are exempt purposes.
Data Protection Officer (DPO): For the same reasons given above, we believe we do not need to appoint a DPO at this business. However, we have designated an Assigned Representative.
Assigned Representative: Although we do not believe that we need to appoint a DPO, we have created the role of Assigned Representative who is a Director, who will take on the responsibility for acting as the point of contact for data subjects, enquiries regarding data protection issues and for liaison with the ICO, should the need arise. Contact can be made with the Assigned Representative at the above addresses or through the normal contact routes given on the website, addressed to The Assigned Representative.
Purposes for processing personal data
We process your personal data to run our business. The purposes for processing personal data include
- delivery of contracted services, including communications through the following routes: e-mail, telephone, postal
- processing of accounts and record keeping
- staff administration
- organisation of meetings and events
- purchasing of goods and services from our suppliers
- communications with professional advisors, such as accountants.
- communications with state-run organisations, such as HMRC and Companies House
- making and receiving payments through our bank accounts
We have examined the types of personal data we hold and the reasons for us obtaining and processing that data and believe that data and data processing falls chiefly under the following lawful basis:
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
For the avoidance of any doubt, we take the meaning of the term contract in its widest form, to cover all types of contract, either explicit or implicit, whether written or verbal and whether or not any financial transaction takes place.
We believe that some of our data processing also falls under lawful basis Legitimate Interest (see following section).
Our vision was to create a contract-analysis business able to apply surface chemical analysis techniques to the widest range of technological problems for the benefit of academics and industrialists. We have identified that MSA has a legitimate interest in contacting customers, suppliers and potential customers and suppliers to keep them abreast of both MSA’s needs and developments at MSA. To this end, we believe that it is necessary to contact from time to time customers, suppliers and potential customers and suppliers over and above any contact that we may have relating to the execution of any contract that is in place or that is in the process of being negotiated. We believe that using generally available personal data, in addition to that of our existing customers and suppliers, to communicate our activities and needs that would normally be considered to be of interest to customers, suppliers and potential customers and suppliers is not an unreasonable use of said data and would not cause the data subject obvious unwarranted harm.
Recipients of personal data
On the whole, personal data are received and processed by directors or employees of the business for the purposes outlined above, notable exceptions being professional advisors, such as accountants, HR consultants, web- and e-mail-service providers and state bodies/agencies, such as HMRC and Companies House. We do not pass on or sell your details to any third parties for their own commercial use.
Transfers to any third-countries or international organisations
Data are held on our own servers, which are within the European Economic Area. Data may also be held on the mail servers of Zen, an internet service provider registered with the Information Commissioner’s Office.
MSA has been in existence since 2011. It is quite common for customers, or colleagues of former customers, to make enquiries regarding analysis that we carried out for them many years prior in relation to some current analytical need. Personal data are stored with the data arising out of our analysis of samples. In addition, the equipment we use is highly specialised, often requiring esoteric spare parts or consumables. The ability to search back through records of goods and services procured is invaluable. Ex-employees may make an industrial-injury claim many years after they have left the company. Hence, we have retained all our records extending back to our founding, which we wish to continue under GDPR. Personal data will normally be held in their full form for archiving purposes. Employee’s personal data are normally stored in their full form for up to forty-years following cessation of employment.
Rights available to data subjects
You have a number of rights under GDPR regarding your personal data that we hold and process. You have the right to know what type of data we hold on you, to see what data we hold about you and to make corrections to the data that we hold. You have a right to receive a copy of the data. You have rights in relation to automated decision making and profiling (which we do not carry out). You have the right to object to us processing your data. You have the right to instruct us to delete your data. You have the right to instruct us to restrict the processing of your data. Whilst requests regarding any of your rights can be made verbally or in writing, it would be appreciated if such requests are made in writing through the general contact channels on our website, addressed to The Assigned Representative. We are required to provide you with a response within thirty-days.
Your rights can be somewhat limited, depending upon the lawful basis under which an organisation operates. As we operate chiefly under lawful basis Contract, your rights to erase your data, restrict the processing of your data or object to the processing of your data are limited. However, we may consider a request under your right to erase your data, restrict the processing of your data or object to the processing of your data as a request to also terminate your contract with the business.
Right to withdraw consent.
We hold and process your personal data under lawful purposes Contract and Legitimate Interest. This means that we do not need your consent to hold and process your personal data and neither will we seek your consent. Therefore, whilst you have a right to withdraw consent, you have not given us any consent for you to withdraw.
Right to lodge a complaint with a supervisory authority
We would hope that if you have an issue with any way in which we hold and process your data that you would raise the issue with us in the first instance. Issues can be raised verbally or in writing, but it would be appreciated if such issues are raised in writing through the general contact channels on our website, addressed to The Assigned Representative. Nevertheless, you have the right to raise a formal complaint with the Information Commissioner’s Office regarding what we do with your data, further information about which can be found at www.ico.org.uk.
Statutory or contractual obligation to provide personal data
We hold and process your personal data chiefly under lawful purpose Contract. For a contract to exist with the business, certain personal data must be provided, the specific nature of which is dictated by the nature of the contract. Failure or refusal to provide the required data will result in the contract not proceeding or, in the event of an existing contractual arrangement, terminating.
Automated Decision-making and profiling
We do not use automated decision-making and/or profiling systems.
Website – www.midsurfanalysis.co.uk