Data Protection Policy

1 Introduction

At Mike Golf Security & Investigation, we take data protection seriously.

We are committed to handling personal data lawfully, fairly, securely, and responsibly in accordance with the UK GDPR, the Data Protection Act 2018, and other applicable data protection and privacy laws.

This Data Protection Policy explains the standards we apply to the collection, use, storage, retention, disclosure, and protection of personal data in connection with our website, enquiries, client relationships, security services, investigative services, and related business operations.

2 Our Commitment

We are committed to ensuring that personal data is:

a. processed lawfully, fairly, and transparently;
b. collected for specified, explicit, and legitimate purposes;
c. limited to what is necessary for the relevant purpose;
d. accurate and kept up to date where necessary;
e. retained only for as long as reasonably necessary; and
f. protected by appropriate technical and organisational security measures.

3 Scope of This Policy

This policy applies to personal data processed in connection with:

a. website enquiries and communications;
b. prospective and current client matters;
c. security, investigative, tracing, surveillance, and process serving work;
d. billing, administration, and business management;
e. reports, notes, recordings, images, and evidential material; and
f. legal, regulatory, insurance, and operational requirements.

4 Lawful Bases for Processing

We process personal data only where we have a lawful basis to do so.

Depending on the circumstances, we may rely on:

a. contractual necessity;
b. legal obligation;
c. legitimate interests;
d. consent; or
e. vital interests in an emergency.

Where special category data or criminal offence data is processed, we will only do so where an additional lawful condition applies under applicable law.

5 Types of Data We May Process

Depending on the nature of the matter, we may process personal data including:

a. names, addresses, email addresses, telephone numbers, and other contact details;
b. dates of birth and identifying details;
c. client, case, and instruction-related information;
d. billing, payment, and transaction information;
e. correspondence, notes, and communication records;
f. photographs, video, audio, logs, statements, reports, and service records;
g. publicly available information and lawfully obtained background information; and
h. website usage, technical, device, analytics, and cookies-related information.

Depending on the nature of the work, this may include special category data or criminal offence data where lawful and necessary.

6 Purposes of Processing

We may process personal data for purposes including:

a. assessing and responding to enquiries;
b. verifying identity, instructions, and authority;
c. conducting lawful security and investigative services;
d. carrying out tracing, surveillance, background enquiries, and process serving activities;
e. documenting events, service attempts, interactions, and relevant activity;
f. preparing reports, evidence packs, and related deliverables;
g. managing billing, payments, and debt recovery;
h. maintaining internal records, quality assurance, and compliance processes;
i. protecting our business, personnel, systems, and legal position; and
j. complying with legal, regulatory, insurance, and professional obligations.

7 Recording Equipment and Evidential Material

In certain circumstances, we may use recording equipment or collect evidential material in connection with the lawful provision of our services.

Any such use will be carried out only where we consider it justified, lawful, necessary, and proportionate.

Recordings and evidential material may be used for:

a. lawful surveillance and evidence gathering;
b. documenting relevant activity, events, service attempts, or interactions;
c. supporting operational, evidential, reporting, and legal requirements; and
d. internal review, quality assurance, and complaint handling.

Access to such material is restricted to authorised persons and will only be shared where there is a lawful basis and a legitimate need to do so.

8 Data Security

We apply reasonable and proportionate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, or misuse.

These measures may include restricted access controls, authentication procedures, secure storage of physical and digital records, controlled sharing practices, and periodic review of data handling and security measures.

While we take data security seriously, no method of transmission or storage can be guaranteed to be completely secure.

9 Data Retention

We retain personal data only for as long as is reasonably necessary for the purpose for which it was collected and processed, including for operational, evidential, legal, regulatory, insurance, complaint-handling, and record-keeping purposes.

When personal data is no longer required, we will seek to delete, destroy, anonymise, or securely archive it as appropriate.

10 Sharing and Disclosure of Data

Personal data may be shared where reasonably necessary and lawful, including with:

a. clients and prospective clients where appropriate;
b. contractors, subcontractors, operatives, agents, and associates engaged in connection with the work;
c. professional advisers, including solicitors, accountants, insurers, compliance advisers, and debt recovery providers;
d. courts, tribunals, regulators, law enforcement authorities, or government bodies where required or permitted by law;
e. specialist service providers and business support providers; and
f. IT, hosting, storage, analytics, and administrative support providers.

We do not sell personal data.

Any sharing of personal data will be limited to what we consider reasonably necessary and lawful in the circumstances.

11 International Transfers

We aim to store and process personal data within the United Kingdom or in jurisdictions that provide an appropriate level of protection.

Where personal data is transferred outside the United Kingdom, we will take reasonable steps to ensure that appropriate safeguards are in place where required by law.

12 Data Subject Rights

Subject to applicable law, individuals may have rights including:

a. the right to be informed;
b. the right of access;
c. the right to rectification;
d. the right to erasure;
e. the right to restrict processing;
f. the right to object;
g. the right to data portability; and
h. rights relating to automated decision-making where applicable.

These rights are not absolute and may be limited, restricted, or disapplied in certain circumstances under applicable law.

13 Exemptions and Restrictions

Because of the nature of our work, there may be circumstances in which we are lawfully entitled to restrict, withhold, or refuse information or action in response to a data protection request.

This may apply, for example, where compliance with a request would be likely to prejudice investigations, legal proceedings, regulatory functions, the prevention or detection of crime, or the rights and freedoms of others.

Any such exemption or restriction will be considered on a case-by-case basis and only where we believe it applies lawfully.

14 Data Breaches

We take actual or suspected personal data breaches seriously.

Where appropriate, we will investigate data incidents, take reasonable steps to contain and assess them, keep records where required, and make notifications where we are legally obliged to do so.

15 Website Data and Cookies

Our website may use cookies, analytics tools, server logs, and similar technologies to operate the site, improve functionality, enhance security, and understand website usage.

Where required by law, consent will be obtained before using non-essential cookies or similar technologies.

You can usually manage cookie preferences through your browser settings or any cookie controls made available on the website.

16 Updates to This Policy

We may review and update this Data Protection Policy from time to time to reflect changes in law, regulation, guidance, operational practice, or our data handling procedures.

The latest version published on this website will apply from the date of publication.

17 Contact

If you have any questions about this Data Protection Policy or about how personal data is handled, please contact us using the contact details published on this website.