Privacy & Cookie Policy

Vaultex Data Privacy Notice – General Company

1.1 What is a Privacy Notice

Vaultex UK Limited (“Vaultex” or “we”) wants to ensure that you understand what we will do with any personal data you share, or we collect about you, how we will use it, and for what purpose. We are also required by data protection legislation to explain certain matters to you. This notice sets out and overrides anything previously communicated to you which is different.

For the avoidance of doubt, this privacy notice does not form part of your contract of employment and we may update it at any time.

1.2 What we collect and use

Vaultex UK Ltd is both the ‘Controller’ and a ‘Processor’ of the personal data you provide to us. As a result of your interaction with Vaultex, we may hold certain personal data about you. Before you share any personal data, you will be required to read the relevant Privacy Notice and/or Cookie policy associated with the data being provided. Our Cookie Policy will also provide confirmation about any data collated as a result of browsing history and what Vaultex will do with that data.

From a security perspective, Vaultex may hold the following data:

• Name, Address, Contact details, Date of Birth, Gender, ID Documentation, Vehicle registration details
• Custodian Name, ID Number, VAN ID Number

We may also process and store the following “special categories” of more sensitive personal information in order to gain access to a Vaultex site:

• Biometric data
  • Finger Vein scan

As such, we will collect, process, and store your biometric data.

1.3 How and why we will use your personal data

In the event we have your personal data, we will process this in line with Vaultex’s legitimate business interests, which include the following examples:

• To verify third-party individuals visiting Vaultex premises
• Controlling all methods of access to Vaultex Site (operations)
• Managing security at Vaultex sites (operations)
• To effectively manage suppliers
• Client Query Resolution
• To contact end clients to advise them of actual discrepancies and missing credits
• To allow Vaultex to undertake a Due Diligence check on third-party consultancy partners
• To verify inbound security vans.
• To allow security teams to complete identification prior to entry for all arrivals to sites
• To track security and H&S accident events at Vaultex
• CCTV Recordings both live and stored images/data
• Marketing (with consent)
• To allow guests to log in the Vaultex Wi-Fi network

If there are circumstances where we feel we need to process data and it is not in line with these reasons, we will provide you with updated notification (or seek your express consent if that is necessary). We are guided by the principle that you should not be surprised by any processing of your personal data that we undertake.

1.4 How, and why, we will use your particularly sensitive personal data

We may process “special categories” of particularly sensitive personal information in the following circumstances:

• To gain access to Vaultex site operations;
• To record and monitor suspicious activity at a site;
• In limited circumstances, with your explicit consent;
• Where we need to carry out our legal obligations and in line with our data policy;
• Where it is needed in the public interest, and in line with our data policy; 
• In relation to legal claims.

1.5 What we do with it

All the personal data we process and/or control is processed both internally and in specific areas, 

• Company Internal Servers and Systems;
• Designated storage areas;
• Witness Call Record Viewer system.

We will need to share your personal data with others from time-to-time, including:

• Our professional advisers, i.e. our accounting and legal advisers if they require that information to provide advice to Vaultex;
• The Financial Conduct Authority, the Bank of England, HM Revenue & Customs and any other regulatory authority that we may be subject to for the purpose of demonstrating compliance with applicable law and regulations;
• Third parties we reasonably consider necessary in order to prevent crime, e.g. the police;
• Our service providers such as Thomson Reuters, Experian, Pinsent Masons

Your personal data may be stored and processed outside of the European Economic Area (EEA) in countries that may have different data protection rules to those in the UK. However, Vaultex will ensure that the transfer of your personal data outside of the EEA will only occur where the appropriate safeguards have been put in place, such as using corporate rules which are binding on the data processors and have been approved by the ICO. If you want to learn more about the details of these safeguards, you should get in touch with us using the contact details at the bottom of this notice.

No third parties have access to your personal data unless the law allows them to do so.

We have an internal data policy in place to oversee the effective and secure processing of all personal data processed and stored at Vaultex.

1.6 How long we keep your Personal Data

Your personal data will only be retained as long as is reasonably necessary. What this means in practice will vary as between different types of data. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, any continued need to process the data and also our legal and regulatory obligations.

We are required under a variety of different legislation to retain data for specific periods, after which time it will be destroyed.

1.7 How will your personal information be kept safe?

We take the security of your personal information very seriously and have internal controls and security measures in place to protect it. Access to your personal information is restricted to employees, workers, and agents that are required to access it. We have cyber security measures in place as set out in our IT Policy and take steps to ensure that third parties who access personal data will only process your personal information on our instruction, subject to a duty of confidentiality. We have procedures to deal with any suspected data breach – please refer to our Data Policy for more details.

1.8 What are your rights?

You have certain rights in relation to your personal data. More information on these can be found in the Data Privacy Policy on the intranet.

You have the right to make a request to get a copy of the personal information that we hold about you. You can also ask us to correct your personal information if it is incorrect. For details about how to do this, contact us by emailing:dataprotection@vaultexuk.com

For further information on Subject Access Requests, please refer to the Data Access Policy found on the intranet.

If you wish to raise a complaint on how we have handled your personal data, you can do so by emailing your complaint to: dataprotection@vaultexuk.com

If you are not satisfied with our response, or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

Cookie Policy

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