GDPR Privacy Statement

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At Source QX Ltd T/A ProtectHear is a private limited company providing ProtectHear® custom moulded earplugs to industry. ProtectHear also by request provides hobby custom moulded earplugs such as Sleep Plugs, Swim Plugs, Shooting Plugs, Motorbike Plugs and Music Plugs to individual consumers.

As a leading provider of custom moulded earplugs, ProtectHear is committed to providing a high calibre solution for all of our customers, as part of that we take data compliance extremely seriously and are pro-active in ensuring the compliance of the data we hold on customers as well as ensuring compliance as a business entity in our own right.

The purpose of this statement is to provide information regarding how and why ProtectHear collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.

Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:

Consent – the individual has given clear consent for you to process their personal data for a specific purpose

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

Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)

Vital Interests – the processing is necessary to protect someone’s life

Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law

Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful basis for processing personal data can be found at ico.org.uk

ProtectHear Marketing and Sales Data

As a company that processes business related data, ProtectHear has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of ProtectHear’s marketing and sales

ProtectHear collects, processes and stores data relating to businesses and decision makers. We believe that the data we process is of individuals within businesses that are likely to have an interest in the ProtectHear® product. Deemed as ‘Legitimate Interest’ this data is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation. Our typical data segmentation includes those within Health & Safety, Human Resources, Production, MD and Owner related job functions, although this list is not exhaustive and other variables may apply. ProtectHear does not collect data on individual consumers, we will only respond to direct enquiries for hobby custom moulded earplugs.

ProtectHear will only ever collect; process and store the essential information required for making contact with the data subjects within a business environment. The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIn).

Other business related data may also be processed including business name, job function, business telephone number, work mobile number, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive Personal Data’.

The data collected will be used to communicate marketing and sales messages relating to the ProtectHear® product, based upon the job function held by the data subject. ProtectHear specifically only sends messages to those we believe are likely to be interested in the ProtectHear® product based upon the organisation they are employed by and based upon their job function within that organisation. Messages from ProtectHear could be delivered via mail, email, social media, telephone or any other business to business (B2B) marketing methods that may be relevant. We do not send messages to individual consumers.

When you send ProtectHear an enquiry or use our quick enquiry form via our website you will be asked to provide your contact details. When you use our Cost Savings Calculator on our website it sends you the results of the calculation by email, we also receive your email address at the same time. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other ProtectHear® products and services that we feel may be of interest to you, it is deemed that as you have visited the ProtectHear website and provided us with your contact information that you are legitimately interested in our products and services. You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email campaign or by sending an unsubscribe email, by informing us by telephone or by contacting us via any of the methods detailed on the last page below.

ProtectHear® Ear Impression Data

ProtectHear holds earplug data records for every pair of earplugs manufactured since the company was formed in April 2000. This data includes the users initial or first name, initial or middle name, surname, employers name, works / clock number, department, specification of earplug supplied, unique serial number with the date that impression was taken, notes field i.e. where replacements are recorded.

ProtectHear will hold this data indefinitely on the basis that should an employee or former employee come back to their employer with a hearing loss claim we will have the records to provide to the employer of the earplugs provided during their employment.

ProtectHear holds this data and processes it under the GDPR legal grounds of ‘contract’ to enable ProtectHear to fulfil your contractual obligations to provide the product and related services. Also ProtectHear may process this data under the legal basis of ‘legal obligation’ should the need arise.

How we Procure Data

At ProtectHear we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. If you have received correspondence from us, we will have procured your data in one of the following ways:

You have requested information from ProtectHear on a previous occasion.
Someone has sent us your e-mail address requesting information about products and/or services be sent to you.
You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future.
We have previously met at an event and your business card or contact details were handed to us willingly.
You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our products.
You have previously connected with a member of our team via LinkedIn and discussed our products.
A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in the ProtectHear® product, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product.
Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly).

Legitimate Interest Assessment (LIA)

ProtectHear has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding ProtectHear and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from ProtectHear in a direct marketing or sales capacity could be legitimately interested in our ProtectHear® product. It is also deemed that direct marketing and sales is necessary in the context of promoting ProtectHear to professionals in business in order to increase awareness of custom moulded hearing protection solutions within the marketplace.

Per the ICO guidance, ProtectHear can confirm:

We have checked that legitimate interest is the most appropriate basis.
We understand our responsibility to protect the individual’s interests.
We have conducted a legitimate interest assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
We have identified the relevant legitimate interests.
We have checked that the processing is necessary and there is no less intrusive way to achieve the same result.
We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests.
We only use individuals’ data in ways they would reasonably expect.
We are not using individual’s data in ways they would find intrusive or which could cause them harm.
We do not process the data of children.
We do not process the data of individual consumers.
We have considered safeguards to reduce the impact where possible.
We will always ensure there is an opt-out / ability to object.
Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA.
We keep our LIA under review every twelve months, and will repeat it if circumstances change.
We include information about our legitimate interests in our privacy notice.

ProtectHear has in-house data verification, we continually cleanse the data held within the CRM system, completing a full cleanse cycle at least once every 12 months. Any records found to be out of date are placed in quarantine and then deleted within the 12 months.

Data Storage and Retention

The data held within the ProtectHear CRM system is processed and stored in the EU within a secure environment.
ProtectHear has a continual cycle of cleansing and refreshing data contained with our CRM system, all data is verified at least once in a 12 month cycle. Any invalid records are placed in quarantine and then deleted within the 12 months.

Data Storage and Retention ProtectHear® Ear Impression Data

ProtectHear will hold this data indefinitely on the basis that should an employee or former employee come back to their employer with a hearing loss claim we have the records to provide to the employer of the earplugs provided during their employment.

Request to Object

In all correspondence with you we will give you the right to object from receiving further correspondence from ProtectHear. On any email campaigns you receive from ProtectHear there will be the option to ‘unsubscribe’ from receiving any further email correspondence. For general emails you receive from ProtectHear there will be an option to ‘unsubscribe’ by sending a return email. If you receive a telephone call from us, you have the right to request not to receive any further calls. ProtectHear has a companywide CRM system; your request to object will be logged within our CRM system to ensure that you do not receive any further calls.

Should you wish to object to receiving communication from ProtectHear, you can do so in a variety of ways:

Please click the ‘unsubscribe’ link at the bottom of campaign emails
For general emails ‘unsubscribe’ by sending a return email
If you have received a call, please tell the representative that you do not wish to receive any further communication
Please call 01507 604322 and ask to speak with the Data Compliance Manager
You can also make your request by emailing: – enquiries@protecthear.co.uk
Or by writing to: – At Source QX Ltd, 18 Eve Street, Louth, Lincolnshire LN11 0JJ.

All requests will be processed within 30 days. Your details will be quarantined to ensure that your details cannot be processed by the ProtectHear CRM system in the future. Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for Deletion

It is important to understand the difference between a right to object and a request for deletion. If you make a request for deletion, we will remove any data we hold about you from the ProtectHear CRM system. This will also mean that we will remove you from our quarantine files. If you are removed from our quarantine files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from ProtectHear®. If you do not wish for us to contact you again about ProtectHear, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.

The option however is yours, and in either case we will process your request within 30 days.

Please make your request in writing by emailing: – enquiries@protecthear.co.uk
Or by writing to: – At Source QX Ltd, 18 Eve Street, Louth, Lincolnshire LN11 0JJ.

Request for Data Held

You may request that we send you all of the data we hold that relates to you.

Please make your request in writing by emailing: – enquiries@protecthear.co.uk
Or by writing to: – At Source QX Ltd, 18 Eve Street, Louth, Lincolnshire LN11 0JJ.

We will process and respond to your request within 30 days; this service will be free of charge.

Review

This policy was last reviewed and updated on the 21.5.2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.

For questions relating to this policy, please contact enquiries@protecthear.co.uk

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