Privacy Policy

Privacy Policy

Keeping your information safe

The Double Glazing & Conservatory Quality Assurance Ombudsman Scheme (DGCOS) (“DGCOS") are committed to protecting and respecting your privacy.

This policy sets out the basis on which we collect and process your personal data and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how DGCOS collects and processes your personal data, including any data you may provide by way of your membership or your employer's membership of DGCOS (the "Scheme"), or the information we gather from you when you engage one of our Scheme members to provide you with products or services or if you contact us direct with an enquiry.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Double Glazing & Conservatory Quality Assurance Ombudsman Scheme is the controller and responsible for your personal data (collectively referred to as "DGCOS", "we", "us" or "our" in this privacy policy).

We have appointed a Quality Advisor who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Quality Advisor using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Quality Advisor in the following ways:

Full name of legal entity: The Double Glazing & Conservatory Quality Assurance Ombudsman Scheme

Email address: [email protected]

Postal address: DGCOS, Centurion House, Leyland Business Park, Centurion Way, Leyland, Lancashire PR25 3GR

Telephone number: 0345 053 8975

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The ICO’s address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 8th October 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Data Protection Principles

We will comply with data protection law, which says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

We will take measures to ensure we comply with the six principles listed above and are able to demonstrate that compliance (Accountability).

Information we may collect about you

We collect and process data about our current, past and prospective members, and their customers, for the installations they undertake, as well as from general enquiries or complaints about us, the fenestration industry, the scheme or its members. We may, therefore, collect and process the following type of data about you if you have signed up to our newsletter, when work is carried out for you by a scheme member, you make an enquiry with us, you are, were or want to be a scheme member, or you are an employee/director of a scheme member, a past scheme member or a prospective scheme member.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, passport and driving licence.

· Contact Data includes billing address, delivery address, email address and telephone numbers.

· Financial Data includes bank account, bank statements and payment card details or, if you are a customer of one of our members, the amounts you spent on the goods and services you bought.

· Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us and, where you are a customer of one of our members, information about the products or services you bought from the member and details of any comment or complaint you may be making about those goods and services.

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

· Profile Data includes your username and password for use of the portal, your preferences, feedback and survey responses.

· Usage Data includes information about how you use our website, products and services.

· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We may also collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, under the terms of a contract we have with you or otherwise to enable you to receive scheme benefits, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services) or deliver the benefits of the scheme to you. In this case, we may have to cancel a product or service you have with us or which you would otherwise be entitled to under the scheme, but we will notify you if this is the case at the time.

How your personal data is collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone (including through mobile messaging and voice-over-IP services such as WhatsApp), email or otherwise. This includes personal data you provide when you:
• call us to make an enquiry
• apply to become a member of the scheme;
• remain as a member of the scheme;
• or we end your membership of the scheme, including any information relating to any appeal about such termination;
• apply for our products or services;
• create an account on our website;
• provide details on our portal in accordance with our membership schemes;

• contact us following your engagement as a customer of one of our members;
• request marketing to be sent to you;
• sign up to our newsletter;
• enter a survey; or
• give us feedback or contact us.

• Indirect Interactions. If you are a customer of one of our members, that member may enter your details on the scheme. This will be in accordance with an arrangement the member has with you. Once your details have been entered we will have direct interactions with you as described above.

• Automated technologies or interactions. As you interact with our website, we will collect Technical Data about your equipment, browsing actions and patterns by using cookies and other similar technologies as set out in our Cookie Policy. We may also receive Technical Data about you if you visit other websites employing our cookies. For more information about how we use cookies and similar technologies, please see our separate Cookie Policy.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers such as Google based outside the UK or search information providers such as Google based outside the UK.
• Contact, Conduct, Financial, Transaction or other Data from providers of technical, payment and delivery services (such as Go Cardless), or from other regulatory or standards oversight bodies or consumer protection bodies based inside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

Uses made of the information

We need all types of information to allow us to perform and administer member services for scheme members, to deal with our responsibilities to the customers of members and to enable us to comply with our legal obligations.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform a contract we have entered into with you, or are about to enter into with you (for example, your membership of DGCOS).
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This will include the processing of membership information for member services and benefits and the administration and provision of those benefits and customer services for the customers of members. This may also include certain direct marketing communications which are regarded as being in our, your, or a third party's legitimate interests.
3. Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, but we may get your consent before sending our own or third party direct marketing communications to you via email or text message. If, however, we have satisfied ourselves that those communications are in our, your, or a third party's legitimate interests, and your fundamental rights do not override those interests, then we will rely on the basis of legitimate interests instead as above. If we have requested your consent, you have the right to withdraw that consent to marketing either by us or by third parties at any time by contacting us using the details provided above. Where we use legitimate interests as our basis for marketing you have a right to object to that marketing and if you do so, we must stop sending you marketing communications.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your, or someone else's, interests (for example in a medical emergency).
2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

Information about Criminal Convictions

We may only use information relating to criminal convictions where the law allows us to do so. This is usually where that processing is necessary to carry out our obligations.

We envisage that we will not hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of scheme membership application processes or we may be notified of such information directly by you in the course of your membership or your employer's membership.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or you have requested to receive our newsletter, and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing [email protected].

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our site. For more information about the cookies and similar technologies we use, please see www.dgcos.org.uk/cookie-policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

We may share your personal data with the parties set out below for the purposes set out in the table above.

· Service providers (including but not limited to QA Scheme Support Services Ltd – CRN: 05836324) acting as processors who provide IT and system administration services and who administer the Scheme and/or who provide outsourced services to the Scheme.
· Credit agencies who will provide credit reports on you if you apply for membership of the Scheme or are a member of the Scheme.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, inspectors, remedial organisations and insurers who provide consultancy, banking, legal, inspections, insurance and accounting services.
· HM Revenue & Customs and other government bodies , Trading Standards, consumer protection bodies, , consumer advisory body (such as Citizens Advice), competent person schemes, standards bodies, regulators, fraud agencies, finance brokers and lenders, organisations within the fenestration industry with whom we wish to share data to enhance and support our member services and consumer protection and other organisations acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
· We may provide Data about you to our designated insurance broker(s) for the scheme and they will provide it to any selected insurer. This data will be used by the broker and the insurer as it is in our and the members’ legitimate interests for this data to be used to provide insurance relating to the work which has been provided. We have carefully assessed this use of data to ensure that it will provide a benefit to the data subject as they will receive the benefit of the cover at no additional cost to themselves. If you require details of the insurer this will be included in the insurance policy provided to you when work is registered with us.

· If you are a customer of a member and you make a complaint about a member or the products or services they have provided to you, we will pass details of you and your complaint to the member unless you ask us not to. However, please be aware, if you are a customer of a member of the scheme and your complaint is very specific to the installation or service you have received from a member, it may be impossible for us to pass on the complaint without disclosing your details. Where you have concerns about your details being passed to the scheme member in this context, we will work with you to agree what information can be passed to the member.
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of time after they cease being customers, for tax purposes.

In some circumstances you can ask us to delete your data: see 'Your Legal Rights' below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

You have a number of rights in relation to your personal information. These are:

• The right to confirm if we are using data about you and to access details about what we are using and how.
• The right to lodge a complaint with the Information Commissioners Office.
• The right to request we rectify any inaccurate data or to have data which is incomplete for the purpose we hold it completed.
• The right to be forgotten. Which is the right to ask us to delete information about you and if it is appropriate to do so, we will do so.

• The right to restrict what we do with data in specific circumstances, including where the accuracy of the data is contested, processing is unlawful or if we only need the data to meet legal requirements.

• The right to receive the data we hold about you in a format you can use to transfer the data electronically elsewhere.
• The right to object to further processing of your data if it is inconsistent with the main reason for which it was collected. You also have the right to object where we are processing your personal data for direct marketing purposes.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Version 3 - 8th October 2024.