Explanation of terms:
- Business owner: refers to Alexander Koratjitis
- Data protection officer: refers to Sarah Koratjitis
- The company: refers to Poulton Plumbing & Heating Services Ltd.
- Service book: refers to the record of customers (including landlords and tenants) who the company (see point 3) completes annual boiler/fire servicing, or landlords’ gas safety inspections.
- The system: refers to and is another name for the service book (see point 4).
- “Legitimate interest” from GDPR wording. Refers to the real, reasonable and understandable reason why we hold existing customers’ details on our system.
- “Reasonable expectation”: refers to the understanding of the company that existing customers expect us to hold their personal information to provide the expected service (annual service/landlords gas safety inspection).
Who we are:
Poulton Plumbing & Heating is a small family run business which has been operating for 8 years. Alex Koratjitis is the owner, and Sarah Koratjitis is the data protection officer (office co-ordinator, sales & marketing). There are two other members of staff (plumbers/heating engineer & apprentice).
We complete plumbing and central heating work for homeowners, landlords and some small businesses.
The personal information we hold:
The personal information of our customers which we hold includes: the customers name, contact number(s), address, email address (where applicable) and the dates of which their appliances are serviced, or gas safety inspection is due.
Why we hold personal information:
- We only hold the personal information of customers for who we have completed work to boilers (installation, repair or service), fires (installation, repair and service) or landlords and their tenants for landlords’ gas safety inspections.
- This information is held so that we can contact the customer when their annual boiler/fire service, or gas safety inspection is due.
- The only other reason we would contact a customer is to inform them about a product or service we are offering (e.g. reduced price service or new product relevant to their lifestyle)
What we do with the personal information:
- The personal information which we hold is held on one office PC and a company laptop. These devices are password protected.
- The information held on these devices is kept in Gas Checker and Sage software, both of which are password protected and only the business owner and data protection officer have access to these passwords.
- Customer details are held for a maximum of five years. If the customer has not been served by us after five years their details are deleted from the system.
Who we share personal information with and why:
- None of the information held is ever shared with any third parties unless agreed by the customer as it is in their best interest and the interest of their appliance (central heating, boiler or other such appliance).
- Information in this instance (see point 1) will be shared with a boiler (or other) manufacturer to arrange warranty repair or other supplier, eg. a plasterer, joiner, electrician etc. at the customers request.
We may collect information about your computer, including where available your IP address, operating system or browser type, for system administration and advertising. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
In line with the data protection and GDPR guidelines we are able to state a “legitimate interest” in the personal information of the customers listed on our system. We have dealt with these customers in the last five years at least annually (once a year) and in the majority of cases more frequently (more than once a year)
As we serve the majority of our customers at least annually there is therefore a “reasonable expectation” that we hold these details on the system because we have annual or more frequent contact with them.
Gaining and recording data:
All customers who the company completes boiler or fire installation, repairs and services for are asked to complete a data compliance letter in which they state that they comply to their personal information being held by the company. An example of a compliance letter is available on request.
Choice/opt-in and opt-out
You will be given the opportunity to opt-in or opt-out to having your contact details used as set out above, at the time your details are submitted. If you no longer wish to receive emails from us, you may opt-out of receiving these communications at any time by one fo the following methods.
- By phoning us on 01253886626
- By emailing firstname.lastname@example.org with “unsubscribe” in the subject line
- By writing to: Data Protection Officer, Poulton Plumbing & Heating, 10 Stanley Avenue, Poulton le Fylde, Lancashire, FY67DP
- Copies of this privacy statement and data compliance letter are available on request.
- Customers have a right to complain to the ICO if they feel there is a problem with the way in which we (business owner and data protection officer at Poulton Plumbing & Heating Services Ltd.) are handling their data.