+44 (0)1768 392 236 Mon - Fri 09:00 - 17:00 The Park • Rickerby • Carlisle CA3 9AA
+44 (0)1768 392 236 Mon - Fri 09:00 - 17:00 The Park • Rickerby • Carlisle CA3 9AA
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GDPR Privacy Policy

The following sets out our lawful basis for data processing (and the extent and circumstances of that processing) under the General Data Protection Regulation (GDPR)

GTL Systems is a manufacturing company specialising in commercial diesel exhaust systems.  As such we operate within a business to business environment.

As a leader in our field, we are committed to providing a high calibre solution for all of our clients, as part of that we take data compliance extremely seriously and are pro-active in ensuring compliance of our business activities.
The purpose of this statement is to provide information regarding how and why GTL Systems collect, process and store data, as well as providing the appropriate contact information should you wish to request the information we hold about you, withdraw from processing or request deletion of any data we hold about you.
Under the EU General Data Protection Regulation (GDPR) there are six lawful bases for processing personal data.  These are detailed as follows:
• Consent – the individual has given clear consent for you to process their personal data for a specific purpose
• Contract – the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
• Legal Obligation – the processing is necessary for you to comply with the law (not including contractual obligations)
• Vital Interests – the processing is necessary to protect someone’s life
• Public Task – the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
• Legitimate Interests – the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Further information regarding the lawful basis for processing personal data can be found at ico.org.uk

GTL Systems Marketing and Sales Data
As an organisation that processes business related data, GTL Systems has assessed all six grounds for lawful processing of personal data and has selected ‘Legitimate Interests’ as the most suitable lawful ground for the processing of data for the purposes of GTL Systems marketing and sales
GTL Systems collects, processes and stores data relating to businesses and decision makers.  We believe that the individuals that we process the data of, are likely to have an interest in GTL Systems’s products.  Deemed as ‘Legitimate Interest’ this is based upon specific criteria including the business industry sector, size of organisation as well as the individual’s job function within the organisation.  Our typical segmentation includes those within fleet management, compliance, business development, MD and owner related job functions, although this list is not exhaustive and other variables may apply.

We will only ever collect, process and store the essential information required for making contact with the data subjects within a business environment.  The personal data we collect is limited to first name, last name, email address, social profiles (limited to LinkedIN) as well as business IP address.  Other business related data may also be processed including business name, job function, turnover and business address, however we will never collect further personal data such as those classed under ‘Sensitive Personal Data’.
The data collected will be used to communicate marketing and sales messages relating to GTL Systems products, based upon the job function held by the data subject.  GTL Systems specifically only sends messages to those we believe are likely to be interested in the GTL Systems product based upon the organisation they are employed by and based upon their job function within that organisation.  Messages from GTL Systems could be delivered via email, social media, via telephone or any other business to business (B2B) marketing methods that may be relevant.

When you send GTL Systems an enquiry or booking form via our website or one of our micro sites you will be asked to provide your contact details. We will use the data you provide to process your request and may use it to inform you by email, telephone or mail about other GTL Systems products and services that we feel may be of interest to you, it is deemed that as you have visited the GTL Systems website and provided us with your contact information that you are legitimately interested in our products and services.  You have the right to object from any method of correspondence at any time, using the unsubscribe button on an email, by informing the telephone operator or by contacting us via any of the methods below.

How we Procure Data
At GTL Systems we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’.  If you have received correspondence from us, we will have procured your data in one of the following ways:
• You have requested information from GTL Systems on a previous occasion
• Someone has sent us your e-mail address requesting information about our articles and/or services be sent to you
• You or someone else has expressly shared your contact details with us for the purpose of receiving information now and/or in the future
• We have previously met at an event and your business card or contact details were handed to us willingly
• You or a business colleague has visited our website and we believe that there is a genuine legitimate interest in our services
• You have previously connected with a member of our team via the LinkedIN and discussed our services
• A member of our team has found your business and your contact details online, believing that your business would genuinely be interested in the GTL Systems product, based upon your job function aligning with our typical customer profiles they have made contact to introduce you to our product
• Your data has been purchased by a registered third party data supplier, which will have been segmented by industry, organisation size and job function based upon our typical customer profiles. (Due diligence checks around GDPR compliance will have been conducted accordingly)

Legitimate Interest Assessment (LIA)
GTL Systems has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO.  Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our correspondence regarding GTL Systems and that in no way would a data subject be caused harm by our correspondence. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, we believe that any individual that receives correspondence from GTL Systems in a direct marketing or sales capacity, could be legitimately interested in the GTL Systems solution.  It is also deemed that direct marketing and sales is necessary in the context of promoting GTL Systems to professionals in business in order to increase awareness of our products in the marketplace.

Per the ICO guidance, GTL Systems can confirm:
• We have checked that legitimate interests is the most appropriate basis
• We understand our responsibility to protect the individual’s interests
• We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
• We have identified the relevant legitimate interests
• We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
• We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
• We only use individuals’ data in ways they would reasonably expect
• We are not using people’s data in ways they would find intrusive or which could cause them harm
• We do not process the data of children
• We have considered safeguards to reduce the impact where possible
• We will always ensure there is an opt-out / ability to object
• Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
• We keep our LIA under review every six months, and will repeat it if circumstances change
• We include information about our legitimate interests in our privacy notice

GTL Systems’s staff team continually cleanse the data held within our CRM systems, completing a full cleanse cycle periocically.  Any records found to be out of date are placed into a deletion queue which is securely purged periodically.

Data Storage and Retention
The data held within the GTL Systems CRM system is processed and stored in the UK within a secure environment.
GTL Systems has a continual cycle of cleansing and refreshing data contained with our CRM system.  Any invalid records are placed into a deletion queue, which is then securely purged periodically.

Request to Object
In all correspondence with you we will give you the right to object from receiving further correspondence from GTL Systems.  On any emails you receive from GTL Systems there will be the option to ‘unsubscribe’ from receiving any further email correspondence.  If you receive a telephone call from us, you have the right to request not to receive any further calls.  GTL Systems has a companywide CRM system, your request to object will be logged within our CRM system to ensure that you do not receive any further calls.
Should you wish to object to receiving communication from GTL Systems, you can do so in a variety of ways:
• Please click the ‘unsubscribe’ link at the bottom of every email
• If you have received a call, please tell the representative that you do not wish to receive any further communication
• Please call us on +44 (0)1768 392 236 tell the representative that you do not wish to receive any further communication

You can also make your request by emailing:
Or by writing to:
Data Compliance, GTL Systems, The Park, Rickerby, Carlisle, Cumbria, England, CA3 9AA.
All requests received by us will be processed within 30 days. Your details will be added to a suppression file to ensure that your details will not be processed by the GTL Systems CRM system in the future.  Please note this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for Deletion
It is important to understand the difference between a right to object and a request for deletion.  If you make a request for deletion, we will remove any data we hold about you from the GTL Systems CRM system.  This will also mean that we will remove you from our suppression files.  If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our CRM system by a member of our sales team who genuinely believes that your business would benefit from GTL Systems products.  If you do not wish for us to contact you again about GTL Systems, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days.
Please make your request in writing by emailing: 
Or by writing to:
Data Compliance, GTL Systems, The Park, Rickerby, Carlisle, Cumbria, England, CA3 9AA.
Request for Data Held
You may request that we send you all of the data we hold that relates to you.  Please make your request in writing;
By emailing:
Or by writing to:
Data Compliance, GTL Systems, The Park, Rickerby, Carlisle, Cumbria, England, CA3 9AA.
We will process and respond to your request within 30 days, this service will be free of charge.

This policy was last reviewed and updated on the 28th November 2018.  Policies are periodically reviewed to ensure compliance with the current compliance environment.
For questions relating to this policy, please contact data-compliance@gtlsystems.com