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Privacy Notice

This notice was last updated on 21st May 2018.

The notice will be reviewed on an annual basis or when a change in legislation and/or practices dictates and any changes will be notified to you by posting an updated version on our websites and/or by contacting you via email.

We recommend that you regularly check for changes and review this Notice when visiting our websites.

1. Introduction

The Commercial Services Group is committed to protecting your privacy. We take your privacy seriously and will only use the personal information that we collect from you or that you provide relating to the products and services you have requested from us or whereby you make an enquiry about our products or services.

If you have any concerns or questions relating to this notice, including how to update or access your personal information or to make a complaint, you will find our contact details in the Contact Us section below.

We are providing this privacy notice so you know who we are and what we do with any personal information we may collect.

This Privacy Notice explains:

By providing us with your information you consent to Commercial Services Group using your personal data as described in this notice.

1.1 Who We Are

The Commercial Services Group trades under the following brand names and trading styles:

KCS Kent County Supplies
KCS Professional Services
KCS Fleet
KCS Printworks
LASER Energy
Lumina Energy
CTS Vehicle Services
Landscape Services
Inspection Services
Waste Management

Our legal entities that we trade under are:

Commercial Services Kent Limited
Commercial Services Trading Limited

Commercial Services Group is a trading style of both Commercial Services Trading Ltd (Reg No. 5858178) and Commercial Services Kent Ltd (Reg No. 5858177). Both companies are wholly owned by Kent County Council and registered in England and Wales.

Our head office address is:

Commercial Services Group
1 Abbey Wood Road
Kings Hill
West Malling
ME19 4YT

Contact Us

If you have any questions, suggestions or complaints about the processing of your personal information please contact our Data Protection Officer (DPO) via email at dpo@commercialservices.org.uk or in writing by using the address below:

Data Protection Officer
Commercial Services Group
1 Abbey Wood Road
Kings Hill
West Malling
ME19 4YT

2. How we collect Personal Information

We may collect personal information in the following ways:

When you contact us by telephone, email, post or fax and also when you visit our websites.

The type(s) of information collected is likely to include your name, your job title, the company/business you work for and your contact details which could include your telephone number, email address and postal address along with details of your enquiry, quote or order.

When you visit our websites or social media pages your personal information may be automatically collected by our web servers and/or cookies. This information could include your IP address, the date and the pages that you visit.

Calls may be recorded for training purposes, quality control and for the purpose of capturing details about your enquiry including quotes, orders or sales contracts.

For more details about cookies and how we use them, please read our Cookie Notice.

We may also from time to time collect personal information from other sources outside of the Commercial Services Group. These could include other third party companies and/or other local authorities, other government departments and information that is publically available. The type of information we may collect is outlined above.

3. What Personal Information are we collecting

In order for the Commercial Services Group to provide its products and services it may be necessary for us to collect, maintain and process personal information about you, or the company/business which you work for.

Personal information we may collect includes the following:

In addition to the above our recruitment division (trading names are Connect2Kent and Connect2Staff) may collect the following personal information in relation to candidates and their CV's;

4. Why we are collecting this information

We collect your personal information in order to:

5. Our Legal Bases to processing your Personal Information

There are a number of different legal bases that we may use in order to collect and/or process your personal information. These are listed below;


We will collect and process your personal information with your consent. Examples of this are when you tick a box to receive information on our products and services or to receive a newsletter or quote. When we give you the option to tick a box we will always make it clear what it is that you are consenting to.

You may withdraw your consent at any time by contacting us (see Contact Us page) or by using the unsubscribe links in our direct marketing emails.

Contractual Obligation

When we have a contract with you we will collect and process your personal information in order to fulfil our contractual obligation with you. An example of this is when we are delivering products or services that you have ordered, we will use your contact, address and specific instruction details to deliver them, which may include sharing your details with our delivery provider in order to fulfil and complete your orders.

Legal Obligation

We will use your personal information to comply with our legal obligations. This may mean that we need to provide your personal information to HMRC, DVLA and any other public authority. If requested we will provide the police with personal information to assist them with investigations.

Vital Interest

We may use your personal information should we need to contact you about an urgent safety issue with any of our products or services. This will be done with the intention of reducing or preventing harm.

Legitimate Interest

We may use and process your personal information where we wish to pursue our legitimate interest as a business and in a way that you might reasonably expect us to do so. These interests are:

6. Rights of Access to your Personal Information

Under current data protection law, you as an individual, have a number of rights in relation to the personal information we hold on you.

We may ask you to verify your identity or request more information about you in order for us to fulfil your request.

6.1 Your Right to Correcting and Updating your Personal Information

If any of the information we hold about you, or the business you work for changes, is inaccurate or out of date please contact one of the following divisions or services listed below that holds your information to make the changes.

KCS Our stationery and supplies division sales@KCS4education.co.uk
KCS Professional Services Offering independent professional advice on MFD's, software, AV/IT, managed services sales@kcs4ps.co.uk
KCS Fleet Our fleet services division providing vehicle leasing and telematics sales@kcs4ps.co.uk
LASER Our public sector energy division info@laserenergy.org.uk
Lumina Our energy division providing energy brokerage services info@luminaenergy.co.uk
Connect2Kent Our recruitment provider to Kent County Council info@connect2kent.co.uk
Connect2Staff Our recruitment agency for providing employment opportunities to a wide range of industries info@connect2staff.co.uk
Landscape Services Our landscaping and ground maintenance service info@landscapeservices.org.uk
Inspection Services Our Inspection Services division supporting customers with fire safety guidance info@inspectionservices.org.uk
Vehicle Services Our vehicle maintenance division providing repairs for all types of vehicles info@ctsvehicleservices.co.uk

If you are unable to identify which of our divisions or services holds your personal information please contact info@commercialservices.org.uk and we will direct your enquiry to the relevant team.

6.2 Your Right to Erase your Personal Information

You may ask for your personal information to be erased from our systems by emailing us at the following email address dpo@commercialservices.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

We will comply with your request unless there is a lawful reason for us to continue to use and process your personal information.

6.3 Your Right to Restrict Processing of your Personal Information

You have the right to restrict the processing of your personal information in the following circumstances

6.4 Your Rights to the Portability of your Personal Information

Your right to data portability allows you to obtain and re-use the personal information we hold on you for your own purposes. This will be provided to you in a structured, commonly used and machine-readable format (eg a CSV file). Machine-readable means that software can extract the data for other organisations to use. You can ask us to transfer your personal information directly to another service provider where technically feasible.

6.5 Your Right to Object to the Processing of your Personal Information

You have a right to object about how we process your personal information on the following grounds;

You can exercise your right to object by emailing or writing to us at the following email address dpo@commercialservices.org.uk or by post to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

You can also withdraw your consent and opt out from direct marketing by using the unsubscribe link at the bottom of our marketing emails.

Suppression lists will be maintained to screen against direct marketing information being sent to people who have already exercised their right to object to direct marketing. These lists will be held for compliance purposes only, and this does not affect your rights to be erased.

6.6 Your Rights Relating to Automated Decision Making (including profiling)

You have a right to understand and object to any automated decision making and/or profiling that is being carried out on your personal information.

You will need to make your request in writing to us and send your request to dpo@commercialservices.org.uk.

If you are a Connect2Staff or Connect2Kent candidate you should read our Recruitment Candidate Privacy Notice.

7. Right to lodge a Complaint

You have a right to make a complaint with the supervisory authority if you have any concerns about the collection or processing of your personal information. The supervisory authority is the Information Commissioners Office (ICO) whose contact details can be found on their website ico.org.uk/.

8. How we protect your Personal Information

We take the protection of your personal information seriously and will treat it with care and take appropriate steps to protect it.

What we do to protect your personal information:

9. Data stored or handled outside of the European Union (EU)

Some of the personal information you provide to us may be transferred to countries outside the EU.

The companies we use that are based in the US have certified their compliance with the EU-US Privacy Shield www.privacyshield.gov/list.

10. What special categories of Personal Data are collected

To provide certain services it may be necessary for us to collect personal information which is more sensitive. The special categories of personal information we collect or process may include information about your;

The circumstances in which we handle this personal information is likely to be on the behalf of other organisations and we will be acting as a processor.

If you are a Connect2Staff or Connect2Kent candidate you should read our Recruitment Candidate Privacy Notice.

11. We share your Personal Information

Your personal information may be shared with other divisions of the Commercial Services Group where there is a good reason to do so, for example to tell you about a product or service we reasonably expect you to be interested in. For a full list of our divisions see Who We Are.

Sometimes it will be necessary for us to share your personal information with trusted third parties.

An example of this is when we use a logistics partner to deliver products to you.

We will only provide the information that this trusted third party needs to perform the expected task.

Trusted third parties that are under contract with us have agreed to only use the personal information provided to them for the purpose specified within the contract. All trusted third parties that we work with will be expected to act within current data protection regulations.

We work closely with our third party suppliers to ensure that your personal information is respected and protected.

12. The Profiling we do

On some occasions we may collect or process your personal information using automated decision making systems (a decision made by automated means and without any human intervention). We do this because we want to provide you with information, products and services that are of interest and are most relevant to you.

13. Our Retention Policy

We do not retain your personal information for longer than is necessary.

The length of time we retain your personal information for will be determined by the type of information we collect and the purpose that it has been processed for and/or our obligations under other laws.

For example

If you are a Connect2Staff or Connect2Kent candidate you should read our Recruitment Candidate Privacy Notice.

Candidate statement

If you have any concerns about our retention period please contact the dpo@commercialservices.org.uk.

14. Links to other websites

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