Privacy Policy

1. Introduction

Imperial Security (“Imperial Security”, “we”, “us” or “our”) is committed to protecting and respecting the privacy of all individuals whose personal data we collect and process. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with our security services and website operations.

This Privacy Policy applies to all personal data collected and processed by Imperial Security in connection with:

• The use of our website at imperialsecurity.agency and any associated sub-pages
• The provision of security services to our clients across the United Kingdom, including Security Guards, Door Supervision, Event Security, Hotel and Concierge Security, Corporate Security, Retail Security, Close Protection Bodyguards, Educational Security, Construction Site Security, Warehouse Security, Key Holding, CCTV Monitoring, Mobile Patrol, Night Security, Relief Security, Crowd Management, and Doorman and Bouncer Security
• Enquiries submitted through our website, by telephone, or by email
• Employment and contractor recruitment processes
• Business relationships with clients, suppliers and partners

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please refrain from using our website or providing us with your personal data. If you have any questions about this policy or our privacy practices, please contact us using the details set out in Section 15 of this policy.

2. About Us – Who We Are

Imperial Security is a professional security services company based in London, United Kingdom, providing licensed security solutions to businesses throughout London and across the United Kingdom.

Our registered details are as follows:

Name:  Imperial Security

Registered Address:  152 City Road, London, EC1V 2NX, United Kingdom

Telephone:  0208 088 2878

Email:  info@imperialsecurity.agency

Website:  https://imperialsecurity.agency/

For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Imperial Security is the Data Controller in respect of the personal data we collect and process.

Where we process personal data on behalf of our clients (for example, in the context of CCTV monitoring or access control services), we may act as a Data Processor. In such cases, our processing activities are governed by a data processing agreement with the relevant client.

3. The Legal Framework Governing Our Data Processing

All personal data processed by Imperial Security is handled in accordance with the following applicable legislation and regulatory guidance:

• The UK General Data Protection Regulation (UK GDPR), as retained in UK domestic law under the European Union (Withdrawal) Act 2018
• The Data Protection Act 2018
• The Privacy and Electronic Communications Regulations 2003 (as amended)
• The Human Rights Act 1998
• The Regulation of Investigatory Powers Act 2000 (where applicable to surveillance activities)
• The Security Industry Authority (SIA) licensing and conduct requirements
• Any other applicable UK data protection legislation or regulatory guidance issued by the Information Commissioner’s Office (“ICO”)

We are registered with the Information Commissioner’s Office (ICO) as required under the Data Protection Act 2018. Our commitment to UK GDPR compliance extends across all our service delivery areas, including those involving surveillance, access control and security personnel deployment.

4. Personal Data We Collect

The personal data we collect will depend upon the nature of your interaction with Imperial Security. The following categories of personal data may be collected by us:

4.1 Data Collected From Website Visitors and Enquirers

• Full name and job title
• Business name and type of organisation
• Business address and postcode
• Contact telephone number(s)
• Email address
• The nature of your security enquiry or requirements
• Technical information including your IP address, browser type and version, time zone setting, browser plug-in types, operating system and platform
• Information about your visit, including the full URL clickstream to, through and from our website, pages viewed, page response times, and download errors
• Any other information you voluntarily provide when submitting an enquiry or quote request

4.2 Data Collected From Clients and Their Representatives

• Contact details of the individual(s) responsible for managing the security contract
• Site address(es) and information about the premises or venues to be secured
• Invoicing and payment information (including bank account details for billing purposes)
• Service usage data and incident reports generated during the performance of security services
• Information shared for the purposes of conducting site surveys and risk assessments
• CCTV footage and access control logs where we provide or monitor such systems on your behalf

4.3 Data Collected in Connection With CCTV and Surveillance Services

• Visual images of individuals captured on CCTV systems operated by or on behalf of Imperial Security or our clients
• Footage timestamps and location metadata
• Incident-related footage retained for evidential purposes
• Access control records, including entry and exit logs

4.4 Data Collected From Job Applicants and Security Personnel

• Full name, address and contact details
• Date of birth and photographic identification
• National Insurance number
• SIA licence details and expiry dates
• Employment history and professional references
• Educational qualifications and training certifications
• DBS (Disclosure and Barring Service) check results, including enhanced checks where required
• Right to work documentation
• Emergency contact information
• Health and medical information (only where relevant to performing security duties or required by law)
• Financial information required for payroll processing

4.5 Special Category Data

In limited circumstances, and only where strictly necessary, we may process special category personal data as defined under Article 9 of the UK GDPR. This includes criminal records information obtained through DBS checks in respect of security personnel, and health information where relevant to employment. We only process such data where we have a lawful basis to do so and appropriate safeguards are in place.

5. How We Collect Your Personal Data

We collect personal data through a variety of means, including:

• Directly from you when you complete and submit an enquiry or quotation form on our website
• Via telephone when you contact us to discuss security requirements or make an enquiry
• Through email correspondence
• From you as a client or prospective client during the course of contract negotiations and service delivery
• From job applicants who apply for positions with Imperial Security
• From third-party background screening and DBS checking services in connection with recruitment
• Through the operation of CCTV systems and access control technology at client premises
• Via our website through cookies and similar tracking technologies (see Section 13 for full details)
• From publicly available sources, including the SIA public register of licence holders
• From referees, previous employers or professional bodies where relevant

6. How and Why We Use Your Personal Data

We use personal data only where we have a lawful basis for doing so under the UK GDPR. The lawful bases we rely upon are:

• Consent – where you have freely given, specific and informed consent to the processing of your data for a particular purpose
• Contract – where processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract
• Legal Obligation – where processing is necessary for compliance with a legal obligation to which we are subject
• Legitimate Interests – where processing is necessary for our legitimate interests or those of a third party, and those interests are not overridden by your interests or fundamental rights and freedoms
• Vital Interests – where processing is necessary to protect someone’s life

The specific purposes for which we use your personal data, together with the lawful basis for each, are set out below:

6.1 Responding to Enquiries and Providing Quotes

We process your contact and enquiry information in order to respond to your request and provide you with a quotation for security services. The lawful basis for this processing is Contract (taking steps at your request prior to entering a contract) and Legitimate Interests.

6.2 Delivering Security Services

We process client and site information in order to plan and deliver the security services you have engaged us to provide. This may include deploying security guards, monitoring CCTV systems, holding keys, or managing access control. The lawful basis is Contract.

6.3 Managing Client Accounts and Billing

We process your contact and payment information to manage your account, raise invoices, process payments and maintain accurate financial records. The lawful basis is Contract and Legal Obligation (accounting and tax compliance).

6.4 Employing and Managing Security Personnel

We process personal data relating to our security guards, door supervisors, close protection officers and other staff members for the purposes of recruitment, employment management, payroll, training, scheduling, and compliance with SIA licensing requirements. The lawful basis is Contract, Legal Obligation and Legitimate Interests.

6.5 Conducting Background Checks and Vetting

We process personal data including criminal records information when conducting DBS checks and background vetting of prospective and existing security personnel. This is a statutory requirement for the provision of licensed security services. The lawful basis is Legal Obligation and Substantial Public Interest.

6.6 Incident Recording and Reporting

We record incidents that occur during the provision of security services for the purposes of maintaining accurate records, reporting to clients and, where necessary, providing information to law enforcement authorities. The lawful basis is Legitimate Interests and, where required by law, Legal Obligation.

6.7 CCTV Monitoring

Where we operate or monitor CCTV systems at client premises, we process visual images for the purposes of crime prevention and detection, protection of persons and property, and the maintenance of safety and order. The lawful basis is Legitimate Interests and, where required, compliance with legal obligations. CCTV processing is subject to additional safeguards set out in Section 7.

6.8 Marketing and Communications

Where you have given us your consent or we have a legitimate interest to do so, we may contact you with information about our services, industry updates or relevant news. You may opt out of receiving marketing communications at any time by contacting us at info@imperialsecurity.agency. The lawful basis is Consent or Legitimate Interests.

6.9 Website Improvement and Analytics

We use technical and usage data collected via our website to understand how visitors interact with our site, identify areas for improvement and ensure technical functionality. The lawful basis is Legitimate Interests. Please refer to Section 13 for details of our cookie use.

6.10 Legal Compliance and Dispute Resolution

We may process personal data where necessary to comply with legal obligations, respond to regulatory enquiries, enforce our contractual rights, or defend or pursue legal claims. The lawful basis is Legal Obligation and Legitimate Interests.

7. CCTV and Surveillance Data

Imperial Security operates and monitors CCTV systems at client premises as part of our CCTV Monitoring service. We are committed to conducting all surveillance activities in accordance with the Information Commissioner’s Office CCTV Code of Practice, the Surveillance Camera Code of Practice (Home Office), and all applicable provisions of the UK GDPR and Data Protection Act 2018.

Where we operate CCTV systems on behalf of clients, we act as a Data Processor and the client acts as the Data Controller. In such circumstances, processing activities are governed by a written data processing agreement.

Key principles governing our CCTV and surveillance activities include:

• CCTV systems are only deployed where there is a clear and legitimate purpose, proportionate to the privacy impact on individuals
• Surveillance is limited to areas where individuals have a reduced expectation of privacy (such as commercial premises, car parks, entrances, and common areas)
• Signage is displayed at premises under surveillance to notify individuals that CCTV is in operation
• Access to CCTV footage is restricted to authorised personnel on a strict need-to-know basis
• CCTV footage is retained only for as long as necessary for the purpose for which it was captured, and deleted securely thereafter
• CCTV footage may be disclosed to law enforcement authorities where required by law or for crime prevention and detection purposes
• Individuals who appear in CCTV footage have the right to make a Subject Access Request for footage in which they feature, subject to exemptions applicable to law enforcement and third-party privacy

8. Sharing Your Personal Data

Imperial Security does not sell, rent or trade personal data with third parties for marketing purposes. We will only share your personal data in the following circumstances:

8.1 Service Delivery Partners

We may share relevant personal data with vetted subcontractors, relief security personnel or specialist service providers who assist us in delivering security services to you. All such parties are required to comply with data protection obligations equivalent to those we impose on ourselves.

8.2 Background Screening and Vetting Providers

We share personal data with authorised DBS checking services and background screening companies for the purposes of vetting security personnel. These providers act as Data Processors under contractual data processing agreements.

8.3 Regulatory and Statutory Bodies

We may be required to share personal data with the Security Industry Authority (SIA), the Information Commissioner’s Office (ICO), Her Majesty’s Revenue and Customs (HMRC), the Health and Safety Executive (HSE), or other regulatory or governmental bodies where required by law.

8.4 Law Enforcement Authorities

We may disclose personal data (including CCTV footage) to the police, courts, or other law enforcement agencies where we are legally required to do so, or where it is necessary to prevent or detect crime, or to protect the safety of individuals.

8.5 Professional Advisers

We may share personal data with our legal advisers, accountants, auditors and insurers where necessary for the purposes of obtaining professional advice or managing legal claims.

8.6 Business Transfers

In the event that Imperial Security undergoes a business restructure, merger, acquisition or sale of assets, personal data may be disclosed to the relevant parties as part of that transaction. We will take reasonable steps to ensure the privacy of your data is maintained in such circumstances.

8.7 Client Disclosure

We may share incident reports, access logs and other operational data with the client to whom the relevant security service is being delivered, as part of our contractual obligations.

9. International Transfers of Personal Data

Imperial Security is a UK-based business providing services within the United Kingdom. We do not routinely transfer personal data outside the United Kingdom.

In the limited circumstances where personal data may be transferred to a country outside the UK (for example, in connection with cloud-based IT services), we will ensure that such transfers are made in accordance with UK GDPR requirements, specifically:

• The recipient country has been assessed as providing an adequate level of data protection by the UK Secretary of State
• Appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or Binding Corporate Rules
• The transfer is necessary for the performance of a contract or for legal claims

If you would like further information about the safeguards we apply to international data transfers, please contact us at info@imperialsecurity.agency.

10. Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by law. The following retention periods apply as a general guide:

• Client contact and enquiry data: 3 years from the date of last contact or the end of the business relationship, whichever is later
• Client contract and account data: 7 years from the end of the contract, for the purposes of legal and financial compliance
• Security personnel employment records: 7 years from the date of termination of employment or engagement
• DBS check results: Destroyed securely within 6 months of the outcome decision being made, in accordance with DBS Code of Practice
• Recruitment data for unsuccessful applicants: 6 months from the date of the recruitment decision
• CCTV footage – standard: 31 days, unless retained for longer as evidence in connection with a specific incident
• CCTV footage – evidential: Retained until the conclusion of any investigation, criminal proceedings or insurance claim
• Incident reports and security logs: 3 years from the date of the incident
• Financial records and invoices: 7 years as required under UK tax legislation
• Website visitor data and analytics: 13 months from collection

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures. Where we hold data on behalf of clients as a Data Processor, retention is governed by the terms of the relevant data processing agreement.

11. Your Rights Under UK GDPR

Under the UK General Data Protection Regulation and the Data Protection Act 2018, you have the following rights in relation to your personal data:

11.1 The Right to be Informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data. This is the purpose of this Privacy Policy.

11.2 The Right of Access

You have the right to request a copy of the personal data we hold about you. This is known as a Subject Access Request (SAR). We will respond to your SAR within one calendar month of receiving it, free of charge.

11.3 The Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. We will deal with such requests promptly.

11.4 The Right to Erasure (‘Right to be Forgotten’)

You have the right to request the deletion of your personal data in certain circumstances, including where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other lawful basis for processing. This right is not absolute and may be overridden by legal obligations.

11.5 The Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, for example whilst a dispute regarding accuracy is being resolved.

11.6 The Right to Data Portability

Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to request that it be transferred to another organisation.

11.7 The Right to Object

You have the right to object to our processing of your personal data where we rely on Legitimate Interests as our lawful basis. You also have the absolute right to object to your data being used for direct marketing purposes.

11.8 Rights Relating to Automated Decision-Making and Profiling

You have the right not to be subject to decisions made solely by automated processing, including profiling, which produce significant effects on you. Imperial Security does not currently carry out solely automated decision-making that produces legal or significant effects on individuals.

11.9 How to Exercise Your Rights

To exercise any of your rights, please contact our Data Protection contact using the details in Section 15. We may need to verify your identity before processing your request. We will respond within one calendar month of receiving your request. Where a request is complex or numerous, we may extend this period by a further two months, notifying you accordingly.

There is no charge for exercising your rights unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to comply with the request.

12. Data Security

Imperial Security takes the security of personal data very seriously. We have implemented appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include:

• Restricted access to personal data on a strict need-to-know basis
• Password-protected systems and encrypted storage for sensitive data
• Secure physical storage of paper-based records where applicable
• Regular review and testing of our security measures
• Staff training on data protection obligations and information security
• Vetting and confidentiality obligations for all personnel who handle personal data
• Incident response and breach notification procedures

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the ICO within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay where the risk is assessed as high.

Where we use third-party service providers to process personal data on our behalf, we require them to implement appropriate security measures and to process data only in accordance with our instructions.

13. Cookies and Website Tracking Technologies

Our website at imperialsecurity.agency uses cookies and similar tracking technologies to improve user experience, analyse website performance and support our online enquiry functionality.

13.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites function efficiently and to provide information to the website owner.

13.2 Types of Cookies We Use

• Strictly Necessary Cookies: These are essential for the website to function properly and cannot be switched off. They are typically set in response to actions made by you, such as setting your privacy preferences or filling in forms.
• Performance and Analytics Cookies: These cookies collect anonymous information about how visitors use our website, such as which pages are visited most often. We use this information to improve our website. All information collected is aggregated and anonymous.
• Functionality Cookies: These cookies enable our website to provide enhanced functionality and personalisation, such as remembering your preferences.
• Targeting and Advertising Cookies: These cookies may be set by us or by third-party advertising partners to build a profile of your interests and show you relevant advertisements. You have the right to opt out of these cookies.

13.3 Managing Cookies

When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. You can change your cookie preferences at any time by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

For more information about cookies and how to manage them, please visit www.aboutcookies.org or www.ico.org.uk.

13.4 Third-Party Analytics

We may use third-party analytics services, such as Google Analytics, to help us understand how visitors use our website. These services may use cookies and other tracking technologies. Any data collected is anonymised and aggregated. Google's privacy policy can be found at https://policies.google.com/privacy.

14. Third-Party Websites and Links

Our website may contain links to external websites operated by third parties. This Privacy Policy applies only to our website and our services. We do not accept any responsibility or liability for the privacy practices of third-party websites, and we encourage you to read the privacy policy of any website you visit. The inclusion of a link on our website does not constitute endorsement of that third party’s privacy practices.

15. Children’s Privacy

Our website and services are directed at business clients and are not intended for use by individuals under the age of 18 years. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected personal data from a child, please contact us immediately using the details in Section 16 and we will take steps to delete the information promptly.

In the context of our Educational Security services, where our security personnel are deployed at schools, colleges and universities, we process personal data relating to staff and adult visitors, but we do not retain data about pupils or students. Any incidental CCTV footage captured at educational settings is handled in accordance with the policies and instructions of the educational institution (as Data Controller) and the specific safeguarding protocols applicable to that setting.

16. Changes to This Privacy Policy

Imperial Security reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, legal requirements or business operations. Any changes will be posted on this page with a revised ‘Last Updated’ date.

We encourage you to review this Privacy Policy periodically to remain informed about how we are protecting your data. Where changes are material, we will make reasonable efforts to notify affected individuals, for example by placing a prominent notice on our website or contacting you directly.

Your continued use of our website or engagement with our services following the publication of a revised Privacy Policy constitutes your acknowledgement of the amended terms.