Privacy Notice

This Privacy Notice tells you how Rigg Williams Limited trading as Itchenor Sound (“We”, “Us”, “Our”) collects and uses personal data about you in connection with our PA and audio equipment hire business. It is provided to you together with our Hire Agreement Form, Hire Terms and Conditions (Document 1A) and Safety Guidelines (Document 1C). Defined terms used in this Notice but not defined here (for example, Hirer, Business Client, Contract, Equipment) have the meanings given to them in Clause 1 of the Hire Terms and Conditions.

We are committed to protecting your personal data and to complying with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

1. Who we are

The data controller is Rigg Williams Limited (company number 10614784), a company registered in England and Wales, trading as Itchenor Sound.

Registered office: 10 Victoria Road South, Southsea, England, PO5 2DA.

Information Commissioner’s Office (ICO) registration number: ZA251092.

Data protection contact: info@itchenorsound.co.uk.

We have not appointed a statutory Data Protection Officer. Queries and requests about your personal data should be sent to the email address above.

2. Personal data we collect

Depending on the circumstances, we may collect and process the following categories of personal data about you:

  • Identification and contact details: name, home or business address, email address, telephone number.
  • Enquiry data: where you submit an enquiry through the booking enquiry form on our website, the information you provide in that form, including your name, email address, telephone number, the date(s) and approximate times of your event, the event location, a brief description of your event, an indication of the equipment you think you require, whether you wish us to provide Delivery and Collection or Setup and Breakdown, and any further information you choose to include in the message field.
  • Identification verification: a copy of a photo identity document (for example passport or driving licence) and proof of current address, where we require them in accordance with Clause 4.5 of our Hire Terms and Conditions before releasing Equipment.
  • Contract data: the contents of the Hire Agreement Form you sign with us, including the Equipment hired, the Hire Period, the Agreed Venue (where applicable), and the Fees.
  • Vehicle data: where we record the vehicle used to collect Equipment, its registration and make (Clause 5.3(h) of the Hire Terms and Conditions).
  • Payment data: bank account details you provide for payment or refund, and records of the payments we have received from you. We do not store debit or credit card numbers on our systems; card payments are processed by our payment processor.
  • Signature data: your signature (wet-ink or electronic) on the Hire Agreement Form, the Equipment Handover Record and, where applicable, the Cancellation Acknowledgment.
  • Communication data: emails, text and WhatsApp messages, call notes and any correspondence between you and us relating to your hire.
  • Incident and claim data: photographs, notes, witness statements and other evidence gathered where loss, damage, theft or an accident is reported in connection with the Equipment or a hire.
  • Business Client data: where you are a Business Client, your company registered number, registered office, and the name and position of the individual signing for you (and, where clause S1.6 of the Business Client Schedule is activated, a named director giving a personal guarantee).

We do not ordinarily collect “special category” personal data (such as health, racial or ethnic origin, or religious beliefs) from you. If you disclose special category data to us voluntarily (for example in the context of an incident), we will process it only so far as is necessary for the purpose for which you disclosed it.

3. How we collect your personal data

Most of the personal data we hold about you is provided by you directly, when you enquire (including by submitting the booking enquiry form on our website), when you complete the Hire Agreement Form, and during the course of your hire. In limited circumstances we may also receive personal data from others, for example from our insurer if a claim is made, or from the police if a theft is reported.

4. Why we use your personal data, and our lawful basis

We process your personal data for the following purposes, under the lawful bases set out below:

  • To respond to enquiries you submit through the booking enquiry form on our website, or by other means, including providing you with quotations and information about availability. Lawful basis: our legitimate interests in responding to enquiries about our services, and (where your enquiry leads towards a Contract) taking steps at your request prior to entering into a contract (Art. 6(1)(b) and (f)).
  • To agree and perform the Contract with you (preparing the Hire Agreement Form, releasing Equipment, arranging Delivery and Collection, processing payment, handling returns and refunds). Lawful basis: performance of a contract (UK GDPR Art. 6(1)(b)).
  • To verify your identity before releasing Equipment, in accordance with Clause 4.5 of the Hire Terms and Conditions. Lawful basis: our legitimate interests in preventing fraud and protecting our assets (Art. 6(1)(f)).
  • To comply with legal and regulatory obligations, including keeping accounting records under the Companies Act 2006 and the Value Added Tax Act 1994, and responding to lawful requests from HMRC, the police, or other public authorities. Lawful basis: compliance with a legal obligation (Art. 6(1)(c)).
  • To make and defend legal and insurance claims, including recovering sums due, investigating loss or damage to Equipment, and providing information to our insurer or legal advisers. Lawful basis: our legitimate interests in protecting our business and our property (Art. 6(1)(f)).
  • To communicate with you about your hire, including quotations, confirmations, reminders, safety-related messages, and follow-up. Lawful basis: performance of the Contract, and our legitimate interests in managing the hire (Art. 6(1)(b) and (f)).

We do not use your personal data for direct marketing without your consent. We will not sell your personal data to any third party.

5. Who we share your personal data with

We share your personal data only with the following categories of recipient, and only so far as is necessary for the purposes above:

  • Our service providers (processors) that help us operate the business, such as cloud storage providers, e-signature providers (where an electronic signature is used), accounting software providers, email and messaging providers.
  • Web3Forms (operated by Web3Creative, based in India), our website form processor, which receives the booking enquiry form submission from our website and forwards it to us by email. Web3Forms in turn relies on its own sub-processors, namely CleanTalk and Akismet, for spam and abuse prevention (limited to your IP address and email address), and on its hosting provider (currently Amazon Web Services in the United States) for storage of submissions for a short period before automatic deletion.
  • Our professional advisers, including our accountant, our legal advisers, and our insurance broker.
  • Our insurer, Convex Insurance UK Limited, where a claim is notified or may be notified under our policy.
  • Payment providers and banks, to process payments and refunds.
  • Public authorities, including HMRC, the police, courts, and any regulator, where we are required by law to share information or where we consider it proportionate to do so to protect our rights or our property.

Where we use a processor, we enter into a written contract with that processor that binds it to process your personal data only on our instructions and to keep it secure.

6. International transfers

Some of our service providers may process personal data outside the United Kingdom, including in the European Economic Area, the United States, and India. In particular, where you submit the booking enquiry form on our website, that submission is processed by Web3Forms (whose operator, Web3Creative, is based in India) using hosting infrastructure currently located in the United States. Where your personal data is transferred outside the UK, we rely on an appropriate safeguard recognised under UK data protection law, such as an adequacy regulation, the UK International Data Transfer Agreement, or the UK Addendum to the European Commission’s Standard Contractual Clauses.

7. How long we keep it

We keep your personal data only for as long as we need it, subject to the following general guidelines:

  • Hire records (Hire Agreement Form, Handover Record, Cancellation Acknowledgment, correspondence) and associated financial records: six years from the end of the Hire Period. This reflects our accounting obligations under the Companies Act 2006 and the Value Added Tax Act 1994, and the limitation period for contract claims under the Limitation Act 1980.
  • Copies of identity and address verification documents collected under Clause 4.5: for the duration of the hire plus six years, or for so long as we reasonably consider necessary to defend a claim.
  • Incident and claim records (photographs, witness notes, claim correspondence): six years from resolution of the matter, or longer where required by our insurer or by law.
  • Enquiry and quotation records that do not result in a hire: for up to 12 months, after which they are deleted or anonymised.

At the end of the applicable retention period we will securely delete or anonymise the personal data, unless we are required by law to keep it for longer.

8. Your rights

Under UK data protection law you have the following rights in relation to your personal data:

  • The right to be informed about how we use your personal data (fulfilled by this Notice).
  • The right of access to the personal data we hold about you.
  • The right to have inaccurate personal data rectified.
  • The right to have your personal data erased in certain circumstances.
  • The right to restrict our processing of your personal data in certain circumstances.
  • The right to data portability in certain circumstances.
  • The right to object to our processing of your personal data in certain circumstances, including where processing is based on our legitimate interests.
  • The right to withdraw consent, where we are processing your personal data on the basis of consent (this will not affect the lawfulness of processing before withdrawal).

To exercise any of these rights, please email us at info@itchenorsound.co.uk. We will respond within one month. We may need to verify your identity before acting on a request.

9. Automated decision-making

We do not make decisions about you based solely on automated processing, and we do not carry out profiling on your personal data.

10. Complaints

If you are not satisfied with how we have handled your personal data, please contact us first at info@itchenorsound.co.uk so that we can try to resolve the matter.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection:

  • Website: ico.org.uk
  • Telephone: 0303 123 1113
  • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

11. Changes to this notice

We may update this Privacy Notice from time to time. Where we make a material change we will notify existing Hirers by email. The version number and date at the top of this Notice show when it was last updated.