Privacy & Data Protection
At MCL, we are committed to:
- Respecting the privacy of all of our customers, partners, suppliers and employees;
- complying to applicable data protection laws;
- providing products and services that enable our customers to comply to applicable data protection laws; and
- being transparent in how we process your personal data.
What we do with your personal data
We process personal data only for the purpose for which they are collected. The purpose is dependent on whether you use only our website, our services or you are a supplier. If you use our services you are required to register and we collect your personal data. We use this personal data for the provision of the service or the performance of the contract. We may use your personal data for other similar purposes, including marketing and communications, but that will only occur in the case we have your consent or another legal justification for doing so.
The tables below contain the results of MCL’s data mapping across its internal departments, hence some results are duplicated as this reflects the data across multiple internal departments.
From our Consultants and Contractors we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Supplier Management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Business operations and due diligence | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Customer support | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Service delivery | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Sales and Distribution of Products and Services | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Information, system, network and cyber security | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Site management and security | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Supplier Management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Video surveillance | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Budget management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Organisation’s administration and management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
From our Customers and Clients we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Business operations and due diligence | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Debt management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Customer support | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Sales and Distribution of Products and Services | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Service delivery | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Business operations and due diligence | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Customer support | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Information, system, network and cyber security | We have the data subject’s consent | Until contract completed |
| Communications, marketing and intelligence | We have the data subject’s consent | Until consent withdrawn |
| Contact management | We have the data subject’s consent | Until consent withdrawn |
| Customer analysis | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Sales and Distribution of Products and Services | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Service delivery | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Travel and events management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
From our Service Providers and Suppliers we process and retain personal data for the following purposes and periods, with the applicable legal basis.
| Processing purpose | Legal basis | Retention period |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Supplier Management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Administrative enquiries | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Service delivery | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Supplier Management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Service delivery | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until tax or other retention period expires |
| Business operations and due diligence | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Customer support | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Information, system, network and cyber security | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Sales and Distribution of Products and Services | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Site management and security | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Video surveillance | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
| Travel and events management | Necessary for the performance of a contract or for the purposes of legitimate interests pursued by MCL. | Until contract completed |
What personal data do we collect?
The personal data we collect depends on whether you just visit our website or use our services. If you visit our website, you do not need to provide us with any personal data. However, your browser transmits some data automatically, such as the date and time of retrieval of one of our web pages, your browser type and settings, your operating system, the last web page you visited, the data transmitted and the access status, and your IP address.If you use our services, personal data is required to fulfil the requirements of a contractual or service relationship, which may exist between you and our organisation.
We collect:
- Banking Details
- Confidential Correspondence
- Digital Images
- Email, Social Networks
- Financial Details
- Location Information
- Name
- Online Identifiers
- Photographs together with Identifiers
- Telephone contact details
- Visual Images
- Credit History
We collect your personal data from the following indirect sources
| Data subject type | Personal data type | Indirect source name |
| Customers / Clients | Credit History | Cocredo |
| Customers / Clients | Email, Social Networks | Artesian & Intelligent Data Group |
| Customers / Clients | Location Information | Artesian & Intelligent Data Group |
| Customers / Clients | Name | Artesian & Intelligent Data Group |
| Customers / Clients | Online Identifiers | Artesian & Intelligent Data Group |
| Customers / Clients | Telephone contact details | Artesian & Intelligent Data Group |
Who might we share your personal data with?
To maintain and improve our services, your personal data may need to be shared with or disclosed to service providers, other Controllers or, in some cases, public authorities. We may be mandated to disclose your personal data in response to requests from a court, police services or other regulatory bodies. We will ensure that we will disclose only the minimum amount of your information necessary for the required purpose.
We transfer personal data to the following organisations and countries:
| Data subject type | Organisation name | Type | Country |
| Consultants | Anonymised – MCL Customers (with whom a Consultant may work) | Processor | United Kingdom |
| Contractors | Anonymised – MCL Customers (with whom a Contractor may work) | Processor | United Kingdom |
| Service Providers | Anonymised – MCL Customers (with whom a Service Provider may work) | Processor | United Kingdom |
| Suppliers | Anonymised – MCL Customers (with whom a Supplier may work) | Processor | United Kingdom |
| Customers / Clients | Anonymised – Network Carrier (in relation to MCL Customers receiving network services) | Processor | United Kingdom |
| Customers / Clients | Anonymised – Network Carrier (in relation to MCL Customers receiving network services) | Processor | United Kingdom |
| Customers / Clients | Anonymised – Network Carrier (in relation to MCL Customers receiving network services) | Processor | United Kingdom |
| Customers / Clients | HP Enterprise | Processor | United Kingdom |
| Customers / Clients | Anonymised – Hardware Engineering and Maintenance Provider (in relation to MCL Customers receiving hardware maintenance services) | Processor | United Kingdom |
| Customers / Clients | Mitel | Processor | United Kingdom |
| Customers / Clients | Anonymised – Call handling provider | Processor | United Kingdom |
| Customers / Clients | Kyocera Document Solutions UK Ltd | Processor | United Kingdom |
| Customers / Clients | Ricoh UK Ltd | Processor | United Kingdom |
| Customers / Clients | BNP Paribas Leasing Solutions (in relation to client contract with leasing company) | Controller | United Kingdom |
| Customers / Clients | PEAC (UK) Ltd (in relation to client contract with leasing company) | Controller | United Kingdom |
| Customers / Clients | De Lage Landen Leasing Ltd (in relation to client contract with leasing company) | Controller | United Kingdom |
| Customers / Clients | Telefonica UK Ltd (in relation to customers receiving mobile telecoms services) | Controller | United Kingdom |
| Customers / Clients | Anonymised – Telecoms Hardware Supplier | Processor | United Kingdom |
When a Processor or Controller is in a country outside the EU, we apply the necessary safeguards which may include, confirming whether the European Commission approves of transfers to the country or whether we need to use the European Commission’s Approved Model Clauses. Details of these safeguards may be obtained by contacting us directly.
How do we look after personal data
We limit the amount of personal data collected only to what is fit for the purpose, as described above. We restrict, secure and control all of our information assets against unauthorised access, damage, loss or destruction; whether physical or electronic. We retain personal data only for as long as is described above, to respond to your requests, or longer if required by law. If we retain your personal data for historical or statistical purposes we ensure that the personal data cannot be used further. While in our possession, together with your assistance, we try to maintain the accuracy of your personal data.
How can you access your personal data?
You have the right to request access to any of your personal data we may hold. If any of that information is incorrect, you may request that we correct it. If we are improperly using your information, you may request that we stop using it or even delete it completely.
Where you have previously given your consent to process your personal data, you also have the right to request that we port or transfer your personal data to a different service provider or to yourself, if you so wish.
Where it may have been necessary to get your consent to use your personal data, at any moment, you have the right to withdraw that consent. If you withdraw your consent, we will cease using your personal data without affecting the lawfulness of processing based on consent before your withdrawal.
Our Supervisory Authority
You have the right to lodge a complaint with any Supervisory Authority. See our Supervisory Authority contact details below:-
Information Commissioner’s Office, United Kingdom
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
international.team@ico.org.uk
+44 1625 545 745
www.ico.org.uk
To understand how we process personal data online and offline as a data controller, you can view and download the documents below.
