Privacy Policy

This privacy policy applies between you, the User of this Website, and Spoke Telecom Ltd, the owner and provider of this Website. Spoke Telecom Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at:
https://spoketelecom.com/terms-conditions

and
https://spoketelecom.com/website-terms-conditions/

1. Who we are?

Spoke Telecom Ltd (Spoke) believe in a human approach to
technology and aim to offer innovative solutions in technology, telecoms, connectivity,
support, engineering, security and managed services. To do this we need to
process varying degrees of personal data on our employees, contractors,
business partners, suppliers, website visitors and members of the public.

We are committed to protecting your privacy and complying
with the UK Data Protection Act 2018, UK and the General Data Protection
Regulation (collectively referred to as the UK GDPR). We will monitor and
update this policy to reflect changes in these and all other relevant current
and future data protection legislation.

Transparency about all and any data collection is important to us at Spoke. We
will be open about what information we are collecting. Security at Spoke is
paramount and we believe in protecting the confidentiality and security of
information we collect about you; this includes current and prospective clients
and members of the public. This Privacy Notice is intended to bring to your
attention our practices relating to the collection, processing and disclosure
of personal information.

This notice is intended to inform those visitors, not
directly employed by Spoke how we use their data, how we use personal data of
employees is detailed within our internal Employee Privacy Notice.

We may update this Privacy Notice from time to time, and any new Privacy Policy
will automatically be effective when it is published on the website. You should
therefore return here regularly to view our most up to date Privacy Policy.
Feel free to print a copy for your records.

For the purposes of this Privacy Notice, the term “personal information” refers
to personal information relating directly or indirectly to an identifiable
person.

This website is owned and operated by Spoke Telecom Ltd; registered in England
under company registration number 14231389. We are registered with the UK
Information Commissioner’s Office under registration number ZB419730.

2. Personal data we collect

To facilitate the interactions between us and your interest
in Spoke, we may collect and process the following data about you:
●  Personal data when you actively enquire about our services;
●  Name, place of work, position, employer and qualifications;
●  Contact information including telephone numbers, email address, social
media account names;
●  Postal address;
●  Your interests and motives regarding our services, including customer
enquiries and complaints;
●  Relevant information in your day-to-day dealings with the us;
●  Electronic signatures when digitally signing documents;
●  Your image on CCTV if you visit any of our offices or sites;
●  Your device IP or MAC address, system/software name, location, date and
time of interaction;
●  The pages which you visit on our website and the method in which you
found our website;
●  Various information stored in third party cookies.
●  Details of any consents you give such as with newsletter signups.
The information that is processed about you is dependent on the purpose and
channel of your enquiry. This includes:
● Enquiries for more information about Spoke Telecom;
●  A complaint; and,
●  Job applications (see below).

Some of the information we collect about you may include your sensitive
personal data as defined in the GDPR (please see section 4 below for more
details).
When anyone visits our website, we also store information about the way you
interact with our website through the use of cookies. This helps us to make
sure it is the best possible experience for you. Find out more about the way we
use cookies below.

3. How we collect your personal data

In the main we will collect your personal data directly from
you, however, your information may be received from third parties such as your
employer, a personal representative or recruitment company. We may collect your
personal data when you contact us through our website, by telephone, post,
email or through any other means. Your image may be captured if you visit any
of our sites or offices and if it is necessary to issue you with a temporary
pass card.
We may use publicly accessible information to verify information we are
provided with and to manage and expand our business.

 

4. Sensitive personal data

The GDPR provides a definition for special category data,
more commonly referred to as “sensitive personal data”. This relates to
information concerning an individual’s racial or ethnic origin, political
opinions, religious beliefs, trade union activities, physical or mental health,
sexual life, or details of criminal offences.
In recruitment some sensitive data may be requested on a purely voluntary and
anonymous basis for equality monitoring purposes.

5. How we use personal data for our lawful basis

We will use the information held about you for the purposes
for which it was provided to us as stated at the point of collection (or as may
be obvious in the context of collection). Your personal data will be used by us
in the following ways:

● To respond to your enquiries;
● To send you information you have requested;
● To facilitate the business relationship which we have;
● To enter into contractual obligations;
● To improve our business and the service we provide;
● To facilitate any interest in a career at Intercity and;
● For market research purposes;
● To deal with any lawful enquiries from an official statutory body.

We do not collect or compile personal data for release or sale to outside
parties for consumer marketing purposes or host mailings on behalf of third
parties.
In order to process your personal data, we must have a lawful reason, the main
lawful reasons Spoke utilise to process your personal information are: –

● Your implied, or explicit consent which you may withdraw at any time;
● The performance of a contract with you for the provision of our services or
to take preliminary steps at your request to enter into one;
● For us to fulfil our legal or regulatory obligations;
● For reasons of substantial public interest; or,
● The purposes of the legitimate interests pursued by us or by a third party.

A legitimate interest is when we have a business or commercial reason to use
your information, so long as this is not overridden by your own rights and
interests. We consider that we have implemented sufficient checks and
protections to ensure that your rights and interests are not unreasonably
intruded on.
NB. You can object to processing on any of these bases at any time and, if you
do so, we will stop processing the personal data unless we can show compelling
legitimate grounds which override your rights and interests, or we need the
data to establish, exercise or defend legal claims – see “Your rights” below.

6. Recruitment

If you apply to work with us, we will use the information
you supply to process your application and to monitor recruitment statistics.
We may need to transfer your details outside of the EU and UK and to other
affiliates or locations in our organisation. We will remind you of these
privacy terms if you apply for a job with us. For some positions we may ask
some pre-qualification questions, such as do you have a driving licence,
however no automated decision making takes place during the recruitment process.
Once a person has taken up employment with us, we will compile a file relating
to their employment. At that stage we will give more details about how we hold
employee data and we will expect the employee to sign up to additional privacy
terms as part of their employment, employment is subject to satisfactory
references.

During the recruitment process you will be invited to provide special category
information about yourself including details of your religion, sexuality and
ethnic origin. This is wholly voluntary and will purely be used for statistical
purposes to assist with our equal opportunities ambition. For some positions
you may be invited to take a psychometric test to assist us with our decision
making, this is not mandatory and will be performed with your explicit consent.

If you apply to work with us through a third party, such as a recruitment
agency, please also check their privacy policy before proceeding and please
note, some recruitment websites utilise location services to offer you local vacancies,
this information is held by the recruitment agency and not Spoke. Spoke have an
active social media presence, Spoke do utilise LinkedIn and other business
networking channels to identify potential candidates and approaches to
individuals via these channels will be undertaken in line with the platform
terms of business.

We do not encourage unsolicited approaches either directly from individuals or
from third parties, however, if an unsolicited approach is made please ensure
all parties have read and understood this privacy policy.

We may retain details of candidates who may be of interest to us, either now or
in the future, usually for a period of 12 months; on the anniversary of your
application, you will be invited to extend the retention period further. We are
happy to delete your information sooner, just contact us using the contact
details below or email info@spoke.technology

We may use third parties to consider potential hires. We may also verify
details in your application and make what we consider to be reasonable and
necessary background checks about you. These background checks may require a
3rd party to contact you and obtain information.

 

7. Your rights

You have the following rights under the General Data Protection Regulation
(GDPR):

Right to be informed

● You have the right to be informed about the collection and use of your
personal data. There are a few circumstances when Spoke do not need to provide
you with privacy information, such as if you have already given us information
or if it would involve a disproportionate effort for us to provide it to you.
● Any information we will provide will be concise, transparent, intelligible,
easily accessible, and it must use clear and plain language.

Right to access your personal data

● You have the right to make a data subject access request (DSAR). Requests
should be made to the Data Protection Officer. Contact details can be found in
section 12.

Right to have your information corrected

● We take all reasonable steps to ensure that the information we have about you
is accurate and where necessary kept up-to-date. If you think that the
information, we hold is not accurate or up- to-date, please tell us as soon as
possible and we will ensure it is corrected. Please let us know if the personal
data that we hold about you needs to be updated by contacting us at info@spoke.technology
or call us on 03300 562 444.

Right to erasure

● You have a right to have your personal data erased. This is also known as the
‘right to be forgotten’. The right is not absolute and only applies in certain
circumstances.

Right to restrict processing

● GDPR gives you the right to restrict the processing of your personal data in
certain circumstances. This means that you can limit the way that Spoke uses
your data. This is an alternative to requesting the erasure of your data. When
processing is restricted, Spoke are permitted to store your personal data, but
not use it.

Right to data portability

● The right to data portability allows you to obtain and reuse your personal
data for your own purposes across different services. It allows you to move,
copy or transfer personal data easily from one IT environment to another in a
safe and secure way, without hindrance to usability. This right does not apply
to any information held by Spoke.

Right to object – You have the right to object to the following things:

● Processing based on legitimate interests or the performance of a task in the
public interest/exercise of official authority (including profiling)
● Direct marketing
● Processing for purposes of scientific/historical research and statistics.

Rights related to automated decision-making including profiling

● Automated individual decision-making is a decision made by automated means
without any human involvement.
● The GDPR restricts Spoke from making solely automated decisions, including
those based on profiling, that have a legal or similarly significant effect on
individuals.

Please note that these rights may be subject to some conditions and exceptions.
To exercise any of these rights and make such a request, please use the contact
details provided below.

You also have the right to lodge a complaint with the UK’s data protection
regulator, the Information Commissioner’s Office whose contact details can be
found at the bottom of this notice or directly, here: https://ico.org.uk/

Marketing communications and social media

If you have given permission, we may contact you by mail, telephone and email
about our products and services and invitations to events which may be of
interest to you. If you prefer not to receive any direct marketing
communications from us, you can opt out at any time by clicking the
“Unsubscribe” option in any of the marketing communications we send you or by
contacting us by email or telephone.

Spoke has a presence on social media including LinkedIn. You should view their
privacy policies to understand how they may process your personal data. Please
remember that when you share information publicly on the website, for example a
comment on a blog post it may be indexable by search engines, including Google,
which may mean that the information is made public. 

8. Disclosure of your information

It may be necessary to disclose or share your personal data
with either internal or external parties. We will only do this where it is
strictly necessary for example in connection with our legitimate business
activities, to enforce our policies, comply with our legal obligations or in
the interests of security, public interest or law enforcement. For example, we
may respond to a request by a law enforcement agency or regulatory or
governmental authority. We may also disclose data in connection with actual or
proposed litigation, or to protect our property, security, people and other rights
or interests.

We share your information with third parties who help deliver our products and
services to you. Examples include hosting our web servers, analysing data,
providing marketing and legal assistance, access control services, CCTV
monitoring and providing customer service. These companies will have access to
your personal information as necessary to perform their functions, but they may
not use that data for any other purpose.
We may also share your personal data:

● With our delivery partners, such as contractors in order to fulfil our
contractual obligations.
● With Spoke employees and agents to manage our relationship with you;
● With any third party with whom you have asked us to share your personal data.
We will perform reasonable due diligence on those parties to keep any personal
information both confidential and secure and request that they use the
information solely for the purposes of providing the specified services to us.

If we or any part of our organisation is sold, or some of its assets
transferred to a third party, your personal information, as a valuable asset,
may also be transferred to the acquirer, even if they are not in the same line
of business as us. Our customer database could be sold separately from the rest
of the business, in whole or in a number of parts. Potential purchasers and
their advisors may have limited access to data as part of the sale process.
However, use of your personal information will remain subject to this Privacy
Policy.
Similarly, your personal information may be passed on to a successor in
interest in the unlikely event of a liquidation, bankruptcy or administration.

9. Cookies, other information gathering technologies and links to other sites

Our website may, from time to time, contain links to other
websites, mainly those of our partners and clients, but also those of other
third parties. Please note that these websites have their own privacy policies
and that we do not accept any responsibility or liability for these policies.
Please check these policies before either agreeing to their terms or before you
submit any personal data to these websites or use them.

To allow our site to operate we use cookies which are simply small text files
placed on your computer when you visit this website. 

We also use Google Analytics to gather statistics on site usage and this is
managed by way of consented cookies. There are more details in our cookie
policy and Google’s own privacy policy. Google may aggregate data they collect
from their various services including Google Analytics, Google Translate,
Google Maps and YouTube. Spoke Telecom have no control over Google’s data
collection. You should look at Google’s privacy policy Privacy Policy – Privacy
& Terms – Google for details of their data collection practices.

We shall ask for your permission before we use any non-essential cookies by way
of our cookie banner when you first arrive at the site.

If you have asked us to share data with third party sites (such as social media
sites), their servers may not be secure.
Note that, despite the measures taken by us and the third parties we engage,
the internet is not secure. As a result, others may nevertheless unlawfully
intercept or access private transmissions or data.

 

10. Security

We have put in place security measures that we consider to
be reasonable to protect the security of your personal information and keep it
confidential and to guard against unauthorised or unlawful processing of your
personal data and against accidental loss or destruction of, or damage to, your
personal data. We review these measures regularly to make sure they remain
appropriate. While no system is completely secure, we believe the measures
implemented by Spoke reduce our vulnerability to security problems to a level
appropriate to the type of data involved. We cannot guarantee the security of
any third-party application you may use to transmit your data (for example,
internet browsers).

11. For how long we will keep your information

We will keep your personal information for at least as long
as we have a relationship with you. When deciding how long to keep your
personal information after our relationship with you has ended, we take into
account our legal, regulatory and professional obligations. As a rule of thumb,
we will keep your personal information for as long as is necessary, including:

● To respond to any questions, complaints or claims made by you or on your
behalf;
● To show that we treated you fairly;
● To keep records required by law.

The data we collect. Reason to keep this data and retention period – how
long we will keep it:

Employee data
● Employee files – for legal purposes 7 years after employee leaves
● Employee data Pension data and certificates for medical tests, for example,
eye or hearing tests for legal purposes. indefinitely

Recruitment information
● CVs and applications for unsuccessful candidates will be deleted – legal
obligations 6 months after campaign, unless the candidate has consented to a
longer retention period.

Client information
● All client information – to prove consents and in case of legal disputes 7
years after relationship ends or last activity

Enquiries
● We retain for this period as often enquiries can take this period of time to
come to fruition. 2 years.

Financial Information
● Tax records, payroll etc – for legal purposes 7 years

Analytics
● Semi-anonymous analytical data 25 years

Email broadcasting
● Semi-anonymous analytical data from email interaction 25 years.

12. Where is your information processed?

We endeavour to process your personal data within the UK, or
EEA, however, any transfer of your data will be subject to a European
Commission approved contract or agreement which will safeguard your privacy
rights and give you remedies in the unlikely event of a security breach.

If we transfer your personal data outside of the UK or EEA, we will take steps
to ensure that your privacy rights continue to be protected in compliance with
applicable data protection law and this Privacy Policy.

13. Contact us

If you have any further questions about the way we manage
your data, you wish to activate any of your rights or have a complaint
regarding our data protection practices you can contact the Spoke Telecom Data
Protection Officer using any of the channels below:

● You can email: info@spoke.technology
● You can ring us: 03300 562 444
● You can write: Data Protection Officer, 505B JQ Modern, 120 Vyse Street

Birmingham B18 6NF

 

Spoke Telecom Ltd is a public limited company registered in
England under company registration number 14231389. Registered with the UK
Information Commissioner’s Office under registration number ZB419730.

 

Information Commissioner’s details

Should you remain unsatisfied you can contact the appropriate data protection
regulator listed below.
UK Information Commissioner: Tel: +44(0)303 123 1113 or visit ICO website –
https://ico.org.uk/

Updated March 2025