InVentry Privacy Notice

1.0 Scope

All data subjects whose personal data is collected, is done so in line with the requirements of the GDPR/Data Protection Act 2018.

2.0 Responsibilities

The Data and Safeguarding Manager is responsible for ensuring that this notice is made available to data subjects prior to the school/client organisation collecting/processing their personal data. All Employees/Staff of the school/client organisation who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and that they are aware of the lawful grounds for the processing of their data in relationship to the system.

3.0 Who are we?

lnVentry has been the driving force in visitor management systems since 2010. What started out as the answer to an outdated paper-based system, has now become the market leading sign in and visitor management system in the UK.

There are now over 8,000 schools using lnVentry. Every week we handle more than 9.9 million sign in and out events (that’s up to 85 every second) and capture over 255,000 visitor images.

More than 5 years on and we’re still pushing the technology we use and the industry as a

whole. This constant drive to keep moving forward was recently captured by lnVentry being named in the 21st Fastest Growing Technology Business in the North and being named in the Deloitte Fast 500.

We have now extended our sign in solution beyond education, serving customers in the private and public sectors as well as local government.

lnVentry speeds up the sign in process, keeps identity information secure, and leaves schools feeling confident that their students and staff are safe.

Our Data Protection Officer and data protection representatives can be contacted directly here: dgo@lnVentry.co.uk

4.0 Data being processed

4.1 Depending on the services being requested/provided, the personal data we would like to process on your behalf is:

Personal data type: Source (where InVentry Ltd obtained the personal data from) Lawful Grounds
Staff – For use in Evacuation/communication
First name* Provided by School and extracted from the InVentry System Article 6(1b) Contractual agreement
Surname *
Time signed IN*
Photograph (Only if controller includes this field)
Position (Only if controller includes this field)
Email address
Student – For use in Evacuation
First Name*+ Provided by School and extracted from the InVentry System Article 6(1b) Contractual agreement
Surname*+
Form group*+
Year group *+
Time signed IN*+
Time signed OUT*+
Reason for IN/OUT*+
MIS ID**+
AM/PM session mark**+
Visitor – For use in Evacuation/communication
Title* Provided by School and extracted from the InVentry System Article 6(1b) Contractual agreement
First name*
Surname*
Company*
Photograph*
Vehicle registration*
Name of host/person visiting*
Time signed IN*
Email address
Parent/Carer/Medical Information – For Advances Trip Management Only
Person ID Provided by the school, extracted from the InVentry System and used to facilitate this service. Article 6(1b) Contractual agreement
Contact ID
Title
Contact Name
Parental Responsibility
Relationship
Priority
Telephone Number
Telephone Type
Email Address
Email Type
Court Order
MIS ID
Person ID
Condition Name
Description
Person ID
Dietary ID
Description
Notes
ID Badge service
This service uses a set of data identified by the Data Controller and not specified by InVentry ltd. By using this service, the responsibility for consent lies with the Data Controller. Article 6(1b) Contractual agreement
Support and Fault resolution
This is dependent on the issue identified and the work required to resolve the issue. It may require support to copy the whole database. Before removing data in any form, we will seek your additional consent to do so, either verbally or written, and take all steps to minimise its collection. This data is subject to a stringent internal policy and procedure ensuring that ownership and security of the data is recorded and maintained throughout the process.

By design your InVentry system offers the ability to collect special category personal data in the form of biometric data (facial recognition/finger print recognition). If during the process of fault resolution, we are required to download the database from your system, we will treat it in accordance with the process described above and in line with our data sharing agreement.

Should you so decide, you have the ability to add customised data fields that may include the collection of special category personal data. As the data controller, this is your decision and you should be aware that this will be shared with us. We will treat it in accordance with the above process and in line with our data sharing agreement.

Article 6(1b) Contractual agreement
SMS Service
Mobile number Provided by School, extracted from the InVentry System and used by the SMS provider only to facilitate this service. Article 6(1b) Contractual agreement
Marketing (B2B only)
First name For InVentry customers, this information will be requested from the customer on a consent or contract basis.

For B2B, this information will be obtained via consent or from UK Data House under Article 6 (f) of GDPR. For more details see below.

As we sell via approved resellers, this data may be shared with an authorised reseller solely for communications around InVentry Ltd products once consent has been obtained.

Article 6(1a) Consent

Article 6(1f)

Legitimate Interest

Surname*
Job Title
Email*
Mobile
Landline*
Postcode*
Employment
Personal data contained with CV submitted by candidate directly to InVentry via any appropriate mechanism. This data may be shared for application purposes with the approved recruiter Article 6(1a) Consent
Financial Information
First name This information will be retained for 7 year, in line with financial information for completeness and accuracy of the record. Article 6(1b) Contractual agreement
Surname
Email

Above fields marked with * are required for system functionality, fields marked with a ** are required if using the full MIS register function of the InVentry Evacuation app. Fields marked with a + are not required for InVentry One systems.

The personal data we collect, depending on the role, will be used for the following purposes:

  • Attendance
  • Registration
  • Emergency Evacuation
  • Advanced Trip Management
  • Badge Production
  • Support and fault resolution
  • Marketing

4.3         Our legal basis for processing for the personal data:

  • Article 6(1b) – processing is necessary for the performance of a contract to which the organisation has agreed
  • Article 6 (1f) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party

5.0 Consent

5.1 The data controller is consenting to this privacy notice through the lawful processing condition of performance of a contract, upon the purchase of any of the following licenses; InVentry Anywhere, maintenance or integration. You are giving InVentry Ltd permission to process the personal data supplied specifically for the purpose identified. In doing so, InVentry Ltd must assume that the data has been collected under the terms identified in Article 6 ‘Lawfulness of Processing” of the General Data Protection Regulation and reflected in the Data Protection Act 2018.

Where consent is required for InVentry Ltd to process both types of personal data, it must be explicitly given. Where we are asking you for special category personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting the Data Protection Officer at InVentry using the contact details above or directly through the link provided in any communication.

6.0 Use of data for marketing purposes (B2B purposes only)

6.1 Data used by InVentry Lts for marketing purposes is obtained in the following manner:
From the individual where consent has been obtained directly
From UK Datahouse (https://ukdatahouse.com/) Under Article 6(f) of GDPR – Legitimate Interest where the data has been confirmed to be eligible for use for these purposes and the Privacy and Electronic Commutation (PECR) guidelines.

6.2 Purposes and Intentions:

6.2.1 InVentry’s purpose for processing and storing personal (B2B) data is as follows:
Increased awareness of the product in the market
The opportunity to present a demonstration of the system and potentially sell a system to the organisation (B2B environment only)

6.2.2 Engagement with orgnaisations business only environment contacts to raise awareness of InVentry

  • To arrange meetings to provide a demonstration for interested parties
  • To establish a frequency of contact that suits each individual business.
  • Increased networking opportunities
  • Growth of the business

6.2.3 InVentry’s intentions in using business data are primarily:

  • To engage with organisations business only environment contacts to raise awareness of InVentry
  • To arrange meetings to provide a demonstration for interested parties
  • To enquire about and aim to establish a frequency of contact that suits each individual business

6.2.4 Guidelines and Restrictions:

  • InVentry will remove CTPS exclusions either prior to use or at once upon discovery of CTPS.
  • No non-buisness email addresses i.e. @hotmail will not be used – they must be name@company.com
  • All individuals at businesses will be given a clear route to opt out of future email communications and to apply their rights under current data protection legislation
  • Mobile numbers will not be obtained, recorded or used unless obtained through direct communication with any given business and given out by that business voluntarily to allow InVentry to attempt to contact a given individual.
  • Data obtained for marketing purposes shall not be used for any other purpose

7.0 IP Addresses and Cookies

7.1 In the course of using our site, we automatically track certain information about users, including what browser they are using and their IP address

7.2 The cookies used on our website have been categorised based on information provided by the International Chamber of Commerce UK Cookie Guide.

7.3 For more information please read our cookies policy which can be found at http://inventry.co.uk/cookie-policy/

8.0 CCTV

8.1 CCTV is used in line with the InVentry CCTV policy which is available on request

8.2 Any requests should be submitted to dpo@inventry.co.uk

9.0 Disclosure

InVentry Ltd will not release the information to any third party unless the request is subject to legal obligation without obtaining the express written authority of the partner who provided the information.

10.0 Retention Period

Your InVentry system will process personal data for the following periods;

  • Staff – In line with the organisations data retention policy;
  • Visitors – in line with the organisations data retention policy

InVentry Anywhere Evacuation system

  • Staff/visitors – until 23:59:59 on the day of attendance at site

ID Badge Creation Service

  • Up to 24 hours – UK based Tier 1 Data Centre
  • 51 days from dispatch of order, stored on lock area network at our head office to enable completion and confirmation of order

SMS Service

  • InVentry system – 30 days
  • SMS service provider – 6 months
  • Telecom service provider – 12 months

The message and the number are stored for the above time frames by the SMS service provider for legitimate business reasons and the Telecom service provider as this is regulated under the Investigatory Powers Act 2016.

Email Address

  • For the duration of the communication process

Support Desk

  • Until no longer required under Article 6(f) – Legitimate Interest of the organisation for completeness of the record

Financial Information

  • 7 years under Article 6(f) – Legitimate Interest of the organisation for completeness of the record.

Marketing

  • For 12 months or until consent is withdrawn

11.0 As the Processor

All data hosted by InVentry Ltd is done so in compliance with the requirements laid in GDPR/Data Protection Act 2018/

For more information on storage and processing security, please contact InVentry Ltd using the details above.

InVentry Ltd will support the Data Controller in demonstrating compliance with the regulations covering the UK. Where required and resonable, the processor will work with the data controller to;

  • Cooperate with the relevant data protection authorities in the event of an enquiry
  • Report data breaches to the controller without delay
  • Help the controller to comply with data subject rights
  • Assist the data controller in managing the consequences of data breaches
  • Inform the controller if the processing instructions infringe GDPR/Data Protection Act 2018/

InVentry will take all possible steps to ensure the security of the data where it processes this on behalf of the data controller. However, it cannot be held responsible or liable for the any breach of data that is beyond its control. All requests for additional assistance will be subject to the agreement of the Directors.

Should InVentry choose to change a 3rd party service, we will complete appropriate impact assessments, alter our privacy statement where appropriate and notify you of this change. Where an additional service is being provided, consent will be sought.

12.0 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
  • Right to restriction of processing – where certain conditions apply to have a right to restrict processing
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation
  • Right to object – you have the right to object to certain types of processing such as direct marketing
  • Right to object to automated processing, including profiling – you also have the right to be subject to legal effects of automated processing or profiling
  • Right to judicial review: in the event that InVentry Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 13.0 below.

All of the above requests will be dealt with in line with InVentry Ltd’s Subject Access Procedure and will shared with the customer should a request come from directly a subject.

13.0 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by lnVentry Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and schools/organisation’s data protection representatives.

The details for each of these contacts are:

Supervisory authority contact details Data and Safeguarding Manager contact details
Contact Name: Information Commissioners Office lnVentry Limited
Address line 1: Wycliffe House Visitor House
Address line 2: Water Lane Gelderd Road
Address line 3: Wilmslow Gilderson
Address line 4: Cheshire Leeds
Address line 5: SK9 SA LS27 7JN
Email: registration@ico.org.uk dpo@lnVentry.co.uk
Telephone: 0303 123 1113 0113 322 9253

Document Owner and Approval

The Data Protection Officer is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

Appendix 1 – lnVentry Processing

The following lnVentry data hosting and processing locations are utilised for the purposes described below:

Service System Processing provider Purpose/ Justification Location Article 44 compliance (where required)
Evacuation

service

lnVentry

Anywhere

Rackspace Providing processing

for evacuation service

UK Legally binding contract in place
Asset and compliance management lnVentry Asset and Compliance Rackspace Providing processing for asset and compliance service UK Legally binding contract in place
Badge making lnVentry ID badge making Rackspace Providing processing for badge making transfer UK Legally binding contract in place
Email relay service lnVentry Anywhere Rackspace Provide

communications to visitors

UK Legally binding contract in place
Evacuation service lnVentry Anywhere IBM Providing processing for evacuation service UK Legally binding contract in place
Support desk services ZenDesk ZenDesk Recording details of support calls US/EEA Article 46 – Standard data protection clauses adopted by the Commission in accordance with the examination procedure referred to in Article 93(2)
SMS

messaging

Voodoo SMS Voodoo Sending SMS messages for visitor notifications UK Legally binding contract in place
CRM Dynamics Microsoft Customer management EEA Legally binding contract in place with standard data protection clauses adopted by the Commission in accordance with the examination procedure referred to in Article 93(2)

Service System Processing provider Purpose/ Justification Location Article 44 compliance (where required)
Advanced

Trip Management

lnVentry Anywhere Rackspace Providing processing for the trip management service UK Legally binding contract in place

For further details, please contact dpo@inventry.co.uk

Document dated: March 2021