GDPR (General Data Protection Regulations from 25/05/2018)
Please contact us for details on Data Protection Impact Assessments (DPIAs) and for further information and details for the data protection officer (DPA)
Last Updated: 08/02/2018
Broadgate Privacy and Customer Data Retention Policy
Fair and Lawful Processing
Many of the current regulations and processes Broadgate adhere to require a person to be named as the subscriber for the service. An example of this may be a telephone number or broadband service that cannot be anonymous or unnamed or without an address for installation or emergency services purposes. Person(s) wishing to continue with services should, therefore, offer an alternative to allow Broadgate to continue being able to continue providing existing services.
Information we collect
Broadgate collects different kinds of information. Some of it is personally identifiable and some are non-identifying or aggregated. Here are the types of information we collect or receive:
- Account Information – This includes all the information under your account details within our web portal. It includes names and full contact details for the individual or business that created the account. This is vital for accounting purposes and conforming to our regulatory provisions for providing accurate access to the emergency services.
- Call detail records (CDRs) – This is a record of the communication that has traversed the Broadgate network. It typically includes a source, destination and duration although it can also include quality metrics and fraud prevention data too. CDRs allow us to create an itemised bill for you which forms part of our accounting procedures.
- Payment Records – Broadgate retains a transaction history of purchases made for products and services. This is fundamental to our accounting processes.
- Radius Logs – Broadgate retains data on Broadband sessions such as the time the connection commenced and duration. Broadgate may also log metrics such as sync data and bandwidth used.
- Communicating with Broadgate – We operate systems which log details of calls, emails and web chat correspondence. This allows us to deal with our customers effectively.
- Call Recordings – Call recordings are disabled by default and are opt-in only.
How we use your information (Processing your data)
Broadgate uses your information for the following:
- Providing the Broadgate service and improving our products – To make the product better we have to understand how users are using it.
- Investigating and preventing harmful stuff from happening – We work hard to keep Broadgate secure and to prevent abuse and fraud. This may also include requests from the authorities or courts.
- Communicating with you – Solving your problems and responding to your requests. If you contact us with a problem or question, we will use your information to respond to that request and address your problems or concerns.
- Email messages – We may send you service and administrative emails, such as when we notice that you are nearing credit limits. We may also contact you to inform you about changes in our services, our service offerings and important service-related notices, such as changes to this policy or security and fraud notices. These messages are considered part of the service and you may not opt-out of them.
- Call Recordings – If activated are stored for until downloaded and deleted by yourself.
- Call Detail Records (CDRs) – Are stored for 12 calendar months and then deleted.
- Radius Data – Stored for 6 calendar months and then deleted.
- Account Data – If the authorised account holder chooses to deactivate the account. The data will be archived for no more than 15 years.
- Correspondence – This includes but is not limited to: emails, call-recordings, CDRs, webchats, Fax transmissions and post. The data may be kept for no more than 15 years.
- Payment Data – Broadgate does not process nor retain card payment data. All sensitive transactional payment data is processed and stored in accordance with PCI-DSS regulations by payment providers such as Netbanx or PayPal. Broadgate does store Active Direct Debit details.
- LDAP Data – Customers are in control of LDAP (Hosted Address Directory) data which can be removed permanently via the web-portal.
Sharing and Disclosure
There are times when communications and related content and other user information may be shared by Broadgate. With consent, to comply with legal process, or to protect Broadgate and our users. When we have your consent or if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Broadgate; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive a law enforcement or other third-party request for information we will provide prior notice to the subject of the request where we are legally permitted to do so.
Examples of sharing and disclosure are below and but not strictly limited to the following:
- Example: Telephone number subscriber information is shared between the companies involved in a telephone number port as validation. (Openreach/BT along with the RH, LCP and GCP)
- Example:Fixed line services (Broadband and WLR) require installation addresses, therefore, disclose of this information is given to those involved in the provision and installation of these services.
- Example:Fault finding such as UK PTSN based services sometimes require engineer visits in which case we would ask your permission to provide a contact telephone number and name. These can be from BT Group companies or subcontractors or LLU providers and their subcontractors.
- Example:Direct Debit data is stored and processed with the interbank payment network.
- Example: Some international telephone number rentals require the subscriber to provide official identity documents as a regulatory requirement in that country.
Broadgate takes reasonable steps to protect the information you provide to us as part of your use of the Broadgate service from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the information we collect, process and store and the current state of technology. When you enter sensitive information (such as sign-in credentials) we encrypt the transmission of that information using secure socket layer technology (SSL) and encrypt all data at rest. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. All Broadgate staff are trained and partake in refresher training in data protection.
Data Storage and Transfers
Broadgate does not store or process data outside of the United Kingdom.
Data Subjects Rights
Data Subjects have the rights in relation to their personal data under the Privacy Legislation. Those rights include;
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.
Broadgate may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use Broadgate after those changes are in effect, you agree to the revised policy. If the changes are material, we may provide more prominent notice or seek your consent to the new policy.