Privacy Policy
STATEMENT BY THE DIRECTORS
Purpose of Processing Personal Data
Our organisation processes personal data only where necessary and for defined, lawful purposes. These purposes include:
- Delivering and supporting contracted services, including services that involve or support TransUnion data or systems.
- Managing customer, supplier, and business relationships
- Complying with applicable legal, regulatory, and contractual obligations
- Supporting fraud prevention, identity verification, and risk management activities where applicable
- Protecting the confidentiality, integrity, and availability of personal data through appropriate technical and organisational security measures
- Managing system access, authentication, logging, monitoring, and audit activities
- Detecting, preventing, and responding to security incidents, unauthorised access, or data breaches
- Maintaining records required for governance, compliance, and accountability purposes.
Legal Basis for Processing Personal Data
Personal data is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Depending on the activity, we rely on the following lawful bases:
- Performance of a contract – where processing is necessary to deliver services or meet contractual obligations, including obligations involving TransUnion.
- Legal obligation – where processing is required to comply with applicable laws, regulatory requirements, or statutory obligations.
- Legitimate interests – where processing is necessary for legitimate business purposes such as system security, fraud prevention, risk management, audit, and compliance, and where such interests do not override the rights and freedoms of individuals.
- Consent – where required by law, and where individuals have been provided with a clear choice and the ability to withdraw consent at any time.
Where legitimate interests are relied upon, appropriate assessments are conducted to ensure that the rights and freedoms of data subjects are protected.
Legitimate interests pursued
Our legitimate interests include operating our business, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, and protecting TransUnion data. These interests are balanced against the rights and freedoms of individuals, with appropriate safeguards in place.
Categories of personal data processed
We may collect and process the following categories of personal data, as necessary to provide our services and meet our legal, contractual, and security obligations:
- Identity data – including name, date of birth, title, username, or other identifiers.
- Contact data – including postal address, email address, telephone number.
- Account and access data – including user IDs, login details, access permissions, and authentication information.
- Professional or employment data – including job title, employer name, and business contact details.
- Financial and transactional data – including payment details, billing information, and transaction records (where applicable)
- Technical and usage data – including IP address, device information, browser type, operating system, access logs, and usage activity.
- Security and audit data – including system logs, monitoring records, access records, and incident related information. ‑related
- Communications data – including correspondence, emails, and records of interactions with us.
- Compliance and risk data – including records required for regulatory, audit, or due diligence purposes.
Source of personal data
We may collect personal data about you from:
- you directly
- employers/clients when you apply for a role or are considered for an opportunity.
- referees (where relevant and permitted)
- publicly available sources (for example professional networking sites, business websites, and public records)
- credit reference agencies (CRAs) where required for consumer credit, identity, or affordability checks.
- third party service providers used to support recruitment, screening, and compliance processes.
Recipients / categories of recipients of personal data
We may share personal data with customers or business partners, third-‑party service providers, regulators, or law enforcement bodies where required, and professional advisers. Where data is shared outside the UK, appropriate safeguards will apply.
International data transfers & safeguards
We may transfer personal data to recipients or service providers located outside the UK and/or European Economic Area (EEA).
Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws. These safeguards may include the use of approved standard contractual clauses, international data transfer agreements, or transfers to countries that have been recognised as providing an adequate level of data protection.
Data retention period
We keep personal data only for as long as necessary for its purpose and to meet legal or regulatory obligations. Data used for credit reference or affordability checks is retained only for as long as required and then securely deleted.
Right of access
You have the right to request a copy of the personal data we hold about you and information about how it is used.
Right to rectification
You have the right to request that inaccurate or incomplete personal data is corrected.
Right to erasure
You have the right to request that we delete your personal data where there is no lawful reason for us to continue processing it.
Right to restrict processing
You have the right to request that we limit how we use your personal data in certain circumstances.
Right to data portability
You have the right to receive your personal data in a structured, commonly used, and machine readable format, and to request that we transfer it to another organisation where technically feasible, readable format, and to request that we transfer it to another organisation where technically feasible.
Right to object
You have the right to object to the processing of your personal data where we rely on legitimate interests or where data is used for direct marketing.
Right to complain to the ICO / supervisory authority
You have the right to complain to the UK Information Commissioner’s Office (ICO) or another relevant data protection authority if you are dissatisfied with how we manage your personal data.
Whether provision of data is statutory/contractual & consequences
Provision of Personal Data
Is the provision of personal data statutory or contractual?
The provision of certain personal data is primarily contractual and, in some circumstances, required to meet legal and regulatory obligations.
Personal data is required to:
- enter into and perform contracts with customers, suppliers, or business partners.
- process orders, manage accounts, and deliver goods and services.
- verify identity and prevent fraud; and
- comply with applicable legal, regulatory, accounting, and tax obligations.
What are the consequences of not providing personal data?
If you choose not to provide the personal data, we request:
- we may be unable to enter into a contract with you.
- we may be unable to fulfil orders, supply goods, or provide services.
- we may be unable to conduct necessary verification, compliance, or fraud prevention checks; and
- as a result, our services may be delayed, restricted, or declined.
- Where personal data is requested for optional purposes, such as marketing communications, providing this data is not mandatory, and you may withdraw your consent at any time without affecting your ability to receive goods or services from us.
Automated decision‑making / profiling information
Non-Automated Decision Making and Profiling Making and Profiling Making and Profiling
We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management.
These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.
The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.
Based on this if they DO use Automated Decision Making
Automated Decision Making and Profiling Making and Profiling Making and Profiling
In some circumstances, we may conduct automated decision making or profiling using personal data. This involves the use of automated systems to evaluate certain information about an individual, such as risk factors, affordability indicators, or fraud signals, based on predefined rules or algorithms. Making or profiling using personal data. This involves the use of automated systems to evaluate certain information about an individual, such as risk factors, affordability indicators, or fraud signals, based on predefined rules or algorithms. Making or profiling using personal data. This involves the use of automated systems to evaluate certain information about an individual, such as risk factors, affordability indicators, or fraud signals, based on predefined rules or algorithms.
Where automated decision making is used, it may result in decisions such as the approval, restriction, or rejection of an application or service. Making is used, it may result in decisions such as the approval, restriction, or rejection of an application or service. Making is used, it may result in decisions such as the approval, restriction, or rejection of an application or service.
Individuals have the right to request human intervention, to express their point of view, and to challenge decisions made solely by automated means. Further information about automated decision making and how to exercise these rights can be obtained by contacting us using the details provided in this Privacy Policy. Making and how to exercise these rights can be obtained by contacting us using the details provided in this Privacy Policy‑making and how to exercise these rights can be obtained by contacting us using the details provided in this Privacy Policy
Clarity, accessibility, and transparency
We are committed to being transparent about how we collect, use, and protect personal data.
The information provided in this Privacy Policy is written in clear, plain language and is intended to be easy to understand.
We aim to ensure that information about our data processing activities is concise, accessible, and available in an appropriate format so that individuals can easily understand how their personal data is used and what rights they have.
If any part of this Privacy Policy is unclear or if you require further explanation, you may contact us using the details provided and we will be happy to assist
Credit Reference and Affordability Checks
To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs).
We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.
- Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority
FCA Firm Reference Number: 742313 - TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority
FCA Firm Reference Number: 805757
The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.
Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:
- Creditsafe Privacy / Transparency Notice:
Transparency Notice | Customers & Suppliers - TransUnion CRAIN (Credit Reference Agency Information Notice):
https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference - TransUnion Bureau Privacy Notice:
https://www.transunion.co.uk/legal/privacy-centre/pc-bureau
Identity and contact details of the data controller
- Organisation name – Silurian Security Services Ltd
- Registered address – 86 Margam Road, Port Talbot SA13 2BW
- Contact email or phone number–01639 892795 [email protected]
- Company registration number – 4262091
- ICO registration number – Z2946258

