Customer Privacy Notice
What this Notice covers
Newglaze are committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you.
This notice does not form part of any agreement or contract and may be updated at any time.
Identity of the data controller
We are a data controller for any personal information that you provide to us. This means that we are responsible for determining how information relating to you is used, stored and shared.
Categories of personal data we process
We will collect, store, and use the following categories of personal information about you:
- Your full name
- Your address
- Your contact details such as phone numbers and email addresses
- Your employment status, salary and homeowner status
Sources of personal data
We collect personal information relating to you directly from you.
Our lawful bases for processing your data
We will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you
- Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests
- To comply with relevant legislation and regulations
Our purposes for processing your data
- Performing the contract that we have entered in to with you by providing you with the products and services that you have ordered
- To provide you with a quote and the details of all available payment methods when you have shown an interest in our products and services
- To issue marketing material to you about the products and services we offer
- To process a finance application for you
Sensitive Personal Data
There may be instances where it is necessary for you to share information with us containing special categories of personal information or ‘sensitive personal data’. This relates to things such as details of medical conditions which you may need to share with us so we are able to meet your specific requirements when providing our goods and services.
Due to the sensitive nature of this information, we will only take it from you if you have given us your explicit consent and it is necessary for us to do so. We will also inform you of what we will do with this information and who we will share it with.
Who has access to your data
We may share your personal information with third parties where required by law, where it is necessary to administer the contract we have entered in to you with you, or where we have another legitimate interest in doing so.
Recipients of your data may include third-party service providers, other related business entities, a regulator, or to otherwise comply with the law.
If you choose to fund your purchase with us using one of the finance products we offer to our customers as a credit broker on behalf of lenders, we will share your data with the relevant lender so they are able to process your finance application.
Where we do so, we will require third parties to respect the security of your data and to treat it in accordance with the law.
Security of your data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How we decide how long to retain your data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or contractual requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and any applicable legal or contractual requirements.
You have the right to:
- Request access to, and a copy of, your personal information that we hold.
- Request correction of the personal information that we hold about you if you believe it is incomplete or inaccurate
- Request erasure of your personal information in specific circumstances, such as; if our processing of your personal information is based upon legitimate interests and you believe it is no longer necessary; or if you believe we have processed your personal data unlawfully or not for the purposes which it was intended.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request to restrict the processing of your personal information in specific circumstances, such as; you have requested that your personal information is corrected and want to restrict processing whilst we correct it; where you believe our processing is unlawful but do not want us to erase your personal information; where we no longer need to store your personal information but you require us to do so to enable you to exercise or defend a legal claim.
- Data Portability in particular circumstances meaning that you can request for your personal information to be securely moved, copied or transferred from our IT environment to another. This only applies if our lawful basis for processing your data is consent or performance of a contract, and we are processing your data by automated means.
If you believe we have not complied with your rights, you can complain to the Information Commissioner by visiting their website https://ico.org.uk/.
Automated decision-making & Profiling
We do not conduct any automated decision-making or profiling activities whilst processing your personal information.
Changes to this Privacy Notice
The Company reserves the right to update this privacy notice at any time. You can request the most up to date version from us at any time by contacting us on the contact details below.
Vulnerable Customers Statement
- Policy statement
We are committed to identifying, assessing and managing vulnerable customers in accordance with our own objectives and policy, as well as any regulations and guidelines set out by our regulators.
Implemented are several identification and assessment tools within the procedure section of this document, aimed at identifying, assessing and dealing with all Vulnerable Customer situations and to consistently ensure that our staff are aware of, and knowledgeable about Vulnerable Customers, including how to handle all situations.
We are committed to ensuring that all of our customers are treated fairly and we meet all of their needs to the best of our ability.
We appreciate that sometimes our customers may be vulnerable as a result of a physical or mental health condition suffered by themselves or a family member, age, illiteracy, or if their first language is not English.
This means that we may have to treat vulnerable customers according to their individual circumstances. In order to do so we have employed staff with experience of sales and customer service and given them the necessary training to enable them to identify the signs of vulnerability and how to proceed with that customer.
We ensure that our staff have the necessary training, knowledge, understanding and support in order to be able to identify the potential signs of a vulnerable customer in their dealings with them, and then tailor their approach accordingly.
- Scope and definition
Vulnerability is an extremely subjective area, however our staff are constantly on the lookout for potential signs, such as, a lack of understanding, communication issues and unusual or erratic behaviour.
The FCA defines a Vulnerable Customer as: –
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
The vast majority of our communication with customers is face to face and, in some instances, over the phone, which does however make it easier for our staff to be able to identify both short term causes of vulnerability, such as short-term illnesses or a bereavement, as well as long-term causes, such as mental illness or a disability.
- Processes and procedures
If a member of staff believes that a customer could potentially be vulnerable then they will ask non-intrusive questions in order to understand the customer’s circumstances, allowing them to identify if the customer is in fact vulnerable and how our approach will need to be tailored for that customer.
Any information gathered will be processed in line with GDPR and the Data Protection Act 2018. Where necessary, explicit consent will be obtained from a customer to enable us to process the details of their vulnerability accordingly. Customers will also be fully informed of how we will process this information.
We will always:
- Ask for a customer’s explicit consent in order to record, store or process the details of their vulnerability, where it is necessary and appropriate to do so
- Clearly explain to the customer why we need to record, store or process the details of their vulnerability
- Clearly explain to the customer who the details of their vulnerability will be shared with
Typically, we would only look to process the details of a customer’s vulnerability where we may need to tailor our approach during our communications with them, or when we are entering their home for the purposes of a sales consultation or installation. We would therefore only share the details of the vulnerability with the relevant staff and representatives.
All staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers, this training is delivered on commencement of employment and is refreshed annually.
The various methods for customers to contact us are clearly visible on all communications and our website and provide a choice of ways to communicate with us,
o Face to Face
All our communications verbally or written material is clear, to the point and jargon free.
Where applicable, we try our best to ensure the products/services that we offer are flexible and made to suit the customers’ needs and requirements and where possible deal with the customer’s authorised third-party in a helpful and transparent manner.
All sales visits are followed up with a telephone call and in writing and the benefits and consequences of any product/service are fully explained along with any legal implications.
Where we feel it is needed, additional time is provided between the sales call, written follow up and contractual agreement to allow the customer time to communicate with a third-party and understand the content of the product/service offered.
We ensure that all of our customers do not make a purchase with us or enter into a credit agreement with one of our lender partners without fully understanding what they are entering in to.
When presenting finance options to our customers we do so using our electronic choice of funding software (eCOF) which describes the products clearly and displays the breakdown of each product to the customer. A copy of the bespoke choice of funding is the emailed directly to the customer. Sales representatives also talk through this with customers and explain verbally the information which has been emailed to them.
If we believe that the customer is not fully aware of what they are entering in to then we will:
- Not continue with the sale of any products or services.
- Not continue with any application for credit to fund a purchase.
- Ask if a friend or family member is available to assist the customer, or we will arrange a follow-up appointment when a friend or family member is available.
- Provide the customer with all relevant information in a clear, fair and not misleading manner, allowing them to make an informed decision.
- Not refuse to deal with an individual due to their vulnerability. Instead we will work with them to ensure they are treated fairly.
- Not label different demographics or individuals as vulnerable without understanding their situation. We accept that no two people are the same and each individual should be handled on a case by case basis.
- Where appropriate, we may also signpost customers to agencies such as Citizens Advice or Age Concern UK to seek further guidance and support.
- Monitoring and reviews
The Company carries out regular internal audits and gap analysis monitoring on all business practices and procedures to ensure that our customers, not just those of vulnerable customers objectives are being met.
Regular reviews of the audit results are held with senior management and an ongoing record of gaps, actions and improvements are maintained.
The Company ensure that all staff are provided with the time, resources and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management are responsible for a top-down approach and in ensuring that all staff are included.
Please do not hesitate to contact us regarding any matter relating to this Privacy notice via email to firstname.lastname@example.org, by phone to 01258 483535 or in writing to Newglaze Windows Ltd, 1 Sunrise Business Park, Higher Shaftesbury Road, Blandford Form, Dorset, DT11 8ST.