Lawful Basis For Processing
|To provide your contracted services with Sure or other licenced operators.
Processing is necessary for the establishment, conclusion or performance of a contract with our customers, and as a wholesale service to the customers of other licenced operators
|To provide customer support services in respect of our services
Processing is necessary for the purposes of the legitimate interests of Sure or a third party engaged by Sure to ensure that we are able to provide and maintain high standards of customer care and support.
Calls to our Customer Service Centre are recorded.
|To provide you with updates regarding our services
Processing is necessary in the legitimate interests of Sure to inform its customers of changes to the services that we provide to them such as tariff changes.
|To allow us to review, develop and improve our products and services
Processing is necessary for the purposes of the legitimate interests of Sure is to ensure that its business is carried out effectively with the intention of enhancing our products and services for the benefit of our customers.
|To occasionally carry out market research
Processing is necessary for the purposes of the legitimate interests of the Sure Group, in the Channel Islands and Isle of Man, to evaluate and understand whether the existing services provided meet its customers' expectations and to assess demand for new and additional services in development, as well as assess our performance as compared to our competitors.
|To administer the Sure “Refer a Friend” scheme
Processing is necessary for the legitimate interest of Sure, it’s customers and prospective customers to administer the rewards scheme.
|To send you details of products and services we think will be of interest to you
Processing is necessary for the purposes of the legitimate interests of the Sure Group to communicate with customers on new and existing products, services or other promotions that may be of interest.
Where we do not have your explicit consent, we will perform Legitimate Interest Assessments to ensure you would reasonably expect to receive such communications and that their frequency is not excessive.
Individuals may object to direct marketing by clicking the unsubscribe button on any emails received from Sure; or informing our Customer Service Centre or other Sure representative; or emailing firstname.lastname@example.org.
To provide Directory Information Services, consisting of a printed directory, online version, or a version of the directory accessible from a mobile app. The data used is derived from billing data held by Sure on its customers unless you have requested otherwise
Guernsey – Sure has a legal obligation to provide a directory listing of all fixed line subscribers. You may choose to be ex-directory by informing us that you wish to be ex-directory. For pay monthly mobile phone customers we will rely on your consent to your data being published. The data will consist of name, address and phone number for fixed line customers, and name and phone number for mobile customers. For customers of the other licenced operators you should advise your service provider of your preferences for a directory listing.
Individuals will be able to look up a customer’s phone number using their name and approximate address. Searches to find name from phone number alone, known as Reverse Searches, are not provided.
For those customers who have requested special formatting of their directory listing the processing of this data will be necessary for Sure to meet its contractual obligation.
Jersey – Currently Sure does not publish subscriber data.
IOM – It is the legitimate interest of users of telephone services that there is a directory of subscribers. The names, address and phone number of fixed line subscribers will be published in the Isle of Man Directory unless they have indicated they wish to be ex-directory. Sure does not provide the data of mobile customers in the Isle of Man for publishing.
If you are an Isle of Man customer and wish to be ex-directory you must inform Sure at the time of taking the service or thereafter, either via our retail staff, via email , in writing or calling our Customer Call Centre.
|Collecting personal data for the purpose of identification as part of secure log-in on our websites and apps.
It is the legitimate interest of Sure to ensure the security of it’s websites and apps., and to ensure persons logging into these services are who they purport to be and prevent online crime.
|Collecting personal data from CCTV and door access logs when a customer visits our main office, retail stores, or their Sure sites, to ensure the security of Sure staff, systems and premises including client equipment hosted by Sure.
Processing is necessary for the legitimate interests of Sure to protect its staff and systems, retail stock, as well as client equipment it is contracted to host and to prevent or detect theft. Use of CCTV is a contractual requirement upon Sure, placed by a number of our Enterprise Clients.
|To meet legal, regulatory and ethical obligations applicable to Sure Group.
In order to meet our legal obligations, in certain circumstances this may require us to provide your information to law enforcement agencies or other public bodies.
There are also circumstances where Sure may be requested to process your data for tasks carried out in the public interest, or for the vital interests of a customer or another living individual.
|For purposes of internal training
The processing is necessary for the purposes of the legitimate interests of Sure to improve the customer service and experience it delivers by training its staff.
|Debt collection, fraud prevention and credit checks
It is in the legitimate interest of Sure to minimise the bad debts it incurs through the provision of its contracted services. We may therefore process your data in order to perform a credit check prior to entering into a contract with you, or when a material change in our relationship occurs. Sure does not utilise automated decision making in its processing of your data.
Where an over-due debt is owed to Sure, it is in our legitimate interest to recover the funds owed to us, this may involve processing your data; sharing details of the debt with debt collection services, lawyer or the courts.
It is in the legitimate interest of Sure and It’s customers that Sure undergoes regular Security, Resilience and Financial audits by internal specialists as well as independent auditors. This may involve processing your data.
|Prevent and detect crime
The processing is necessary for the prevention, detection or investigation of crime which may involve the sharing of your image captured on our CCTV, door access data from our systems, or log information regarding your use or interactions with our telecommunications infrastructure, websites, apps., including any misuse of our networks.
|Sharing of personal data
In order to provide contracted services as well as service the legitimate interests of Sure and it’s clients we will share personal data between the Sure entities operating in Jersey, Guernsey and Isle of Man.
We may also share your data with sub-processors and selected businesses partners where they support Sure in providing it’s services. This includes provision of Directory Information Services.
|Acting as a “Data Processor”
For some services that Sure provides its Enterprise customers Sure is classified as a Data Processor, such services include Cloud Services where Sure may store personal data held by the Enterprise customer on Sure equipment. In such cases the data is segregated from personal data that Sure holds in relation to it’s own activities
|Administering Data Subject Rights.
When a Data Subject exercises their rights under the relevant Data Protection Legislation, Sure is legally obliged to process their data, and in some cases the data of third parties in relation to the requests.