Millbeck – Your IoT Connectivity Partner
Here we have information relating to a variety of company policies relating to our websites, business practices and services.
This website millbeck.co.uk (“Our Site”) uses Cookies and similar technologies in order to
distinguish you from other users. By using Cookies, We are able to provide you with a better
experience and to improve Our Site by better understanding how you use it. Please read this Cookie
Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed
to occur if you continue using Our Site. If you do not agree to Our Cookie Policy, please stop using
Our Site immediately or disable Cookies using your web browser settings (details below).
1. Definitions and Interpretation
1.1 In this Cookie Policy, unless the context otherwise requires, the following expressions have the
following meanings:
“Cookie”
means a small file placed on your computer or device by Our Site when you visit certain parts of Our
Site and/or when you use certain features of Our Site;
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations
2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);
“Personal Data”
means any and all data that relates to an identifiable person who can be directly or indirectly
identified from that data, as defined by EU Regulation 2016/679 General Data Protection Regulation
(“GDPR”);
“We/Us/Our”
means Millbeck Communications Limited t, a limited company registered in England under company
number 4501248, whose registered and main trading address is Archway House, 30 High Street,
Wetherby, West Yorkshire, LS22 6LT.
Millbeck Communications Privacy Policy
Millbeck Communications Limited (“Millbeck Communications”) collects business data in order to
provide our services to our business customers. During the relationship there may be times when an
individual’s data is shared with Millbeck Communications, for instance the name of an employee of
the business for contact purposes. This policy covers how we deal with personal data – which is all
data relating to an identified or identifiable individual. We take data protection and complying with
data protection legislation very seriously, please find below how we do this.
Millbeck Communications will be the Controller of the information you provide to us, and that we
collect about you, when you visit our website and when we provide you with, or answer questions
about, our products and services (i.e. Business Broadband, Managed Internet Access, Connecting
Sites and VPNs, Phone lines and Systems, Mobile SIMs). Our contact details are below.
This Privacy Policy gives you detailed information on when and why we collect your information,
how we use it, and how we keep it secure. Please take a moment to read it so you know what
choices and rights you have about the information we may ask you for or collect about you. This
policy may change from time to time so it’s a good idea to come back and read through it every now
and then. If there’s a significant change to the policy, we’ll let you know.
What kind of information do you collect, when and how?
We collect information about you when you:
– Order our products or services (whether via this website, over the telephone or with one of
our field agents);
– Use our products or services;
– Contact us by telephone, email or post, to discuss our products or services or to make a
complaint;
– Visit this website, including speed and service availability checks in your area and different
webforms
To Whom it may concern,
Statement regarding the supply of hazardous and or toxic substances.
Millbeck Communications Limited is paying particular attention to the Evaluation, Authorisation and Restriction of
Chemicals (REACH Regulations) and The Restriction of the Use of Certain Hazardous Substances in Electrical and
Electronic Equipment (RoHS) Regulations.
In this respect of these two pieces of legislation, we are confirming our position as a distributor of aerials, antennas
and GPS systems.
In line with the REACH & RoHS Regulations, we have carried out an evaluation of our downstream supply chain to obtain formal approval and status of products, materials or articles supplied in connection with the above legislation.
REACH Declaration.
We declare that we do not and will not supply any products, materials or articles that contain substances of very high
concern as specified within the REACH Regulations.
MIMODOME antennas do not contain any of the latest ECHA SVHC Candidate List substances above 0.1 w/w %.
Hence, our products are exempt from REACH registration and evaluation and consequently from the pre-registration
process. The following Candidate List was last extended 16th June 2014 and contains 155 substances:
http://www.echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp#download
RoHS Declaration.
We declare that in accordance with Directive 2011/65/EU (RoHS Directive), that the above mentioned product,
materials or articles supplied by Millbeck Communications do not contain the following substances in excess of
defined maximum concentration values, unless exempted in an application by the annex of the RoHS Directive (incl.
amendments).
Substance / Application Maximum concentration values in homogeneous
materials (2011/65/EU – RoHS)
Lead (Pb) 0,1 % (weight) / 1000 ppm (parts per million)
Mercury (Hg) 0,1 % (wt) / 1000 ppm
Cadmium (Cd) 0,01 % (wt) / 100 ppm
Hexavalent Chromium (Cr6+) 0,1 % (wt) / 1000 ppm
Polybrominated Biphenyls (PBB) 0,1 % (wt) / 1000 ppm
Polybrominated Diphenyl Ethers (PBDE) 0,1 % (wt) / 1000 ppm
Millbeck Communications fully supports the intentions of both the REACH and RoHS Regulations is actively engaging
with our downstream supply chain to ensure we and they fully meet the requirements specified within.
If you require further clarification on the matter of REACH then please feel free to contact Millbeck Communications on
the above contact details.
Yours sincerely,
Paul Finder
Director
General Data Protection Regulation Policy
Glossary of Terms
“MCL” – Millbeck Communications Limited
“Data Breach” – the intentional or unintentional release of secure or private/confidential information to an untrusted environment
“Data Controller” – any person or entity which determines the purposes and manner in which any personal data is processed
“Data Processor” – any person who processes data on behalf of the data controller
“Data Protection Impact Assessment” – an assessment to identify and minimise data protection risks where processing is likely to result in high risk to individuals’ interests
“DPO” – The Data Protection Officer appointed under GDPR to monitor internal compliance with data protection obligations, and act as a contact point for data subjects and the supervisory authority
“Data Subject” – the individual who is the subject of personal data
“GDPR” – General Data Protection Regulation
“FOIA” – Freedom of Information Act 2000
“ICO” – Information Commissioner’s Office
“OMG” – MCL’s Operational Management Group
“Personal Data” – Any information relating to an identified or identifiable person
“Service Provider” – any person or company employed by MCL to carry out a function on its behalf
1. Introduction
1.1 The General Data Protection Regulations (GDPR) came into force on 25 May 2018, replacing the EU Data Protection Directive and superseding the Data Protection Act 1998. It was transposed into UK law through the Data Protection Act 2018. The purpose of the GDPR is to protect the rights and freedoms of individuals and ensure that personal data is not processed without their knowledge, and wherever possible, that it is processed with their consent.
1.2 This policy sets out how MCL will handle the personal data it handles in the course of its business, and will comply with the Data Protection principles set out in GDPR.
2. Data Protection Principles
2.1 MCL is committed to processing data in accordance with its responsibilities under data protection legislation.
2.2 Article 5 of the GDPR requires that personal data shall be:
Processed lawfully, fairly and in a transparent manner in relation to individuals;
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
Accurate and, where necessary, kept up to date;
Kept in a form which permits identification of data subjects for no longer than is necessary;
Processed in a manner that ensures appropriate security of the personal data.
3. Data Protection Officer (DPO)
3.1 MCL shall appoint a DPO to support the organisation in upholding the rights of Data Subjects.
3.2 The DPO shall be a Director.
3.3 The DPO shall:
Respond to enquiries from Data Subjects in a timely manner;
Establish and maintain a programme to monitor compliance with this policy;
Establish and maintain a General Data Protection training and awareness programme;
Not be responsible for decisions on how MCL processes personal data on a day-to-day basis;
Be responsible for responding to Data Subject Access requests and FOIA requests;
Report data breaches to the ICO as required;
Be provided with information, resources and support by the OMG.
3.4 The DPO shall create and maintain:
Register of Data Processing Activities
Register of Data Subject Enquiries and FOIA requests
Register of Data Protection Impact Assessments
Register of Data Breaches
Retention and Destruction Policy
3.5 The DPO shall ensure MCL is appropriately registered with the ICO.
3.6 Contact details of the DPO shall be made publicly available.
4. Lawful, Fair and Transparent Processing
4.1 All MCL staff, board members and service providers are responsible for lawful processing.
4.2 Processing must rely on one of: consent, contract, legal obligation, vital interests, public duty or legitimate interests.
4.3 As a statutory body, MCL usually processes data under legal obligation, public duty or contract.
4.4 If consent is used, it must be recorded and revocable.
4.5 MCL shall maintain a Register of Processing Activities.
4.6 Processing must cease where there are no lawful grounds.
4.7 Data shall only be retained per the Retention & Destruction Policy.
4.8 Special Category Data
This includes sensitive data on race, ethnicity, politics, religion, health, sex life, etc.
4.9 Special category processing requires Article 9(2) justification such as:
Explicit consent
Legal obligations
Vital interests
Public availability
Legal claims
Public interest reasons
4.10 Retention & Destruction Policy
4.11 Data should be retained only as necessary. Factors include:
Legal/statutory requirements
Operational needs
Accuracy
Cost/risk
4.12 Personal data must be securely deleted, beyond use.
4.13 Privacy Notices
4.14 A Privacy Notice shall be made available whenever data is collected.
5. Data Security
5.1 Data must be protected against loss, access or misuse.
5.2 MCL shall implement state-of-the-art, appropriate security.
5.3 Security measures must be reviewed regularly.
5.4 Human error is a major risk; staff must be trained.
5.5 Data should not leave MCL premises without DPO knowledge.
5.6 Portable devices must not store personal data.
5.7 Laptops must access data via secure remote login.
5.8 Data transfers must be pre-approved by DPO and IT.
5.9 MCL shall have a Clear Desk Policy.
5.10 Data deletion must be secure, from backups and systems, or by shredding/removal.
6. Sharing of Data
6.1 Third-party processors may be used.
6.2 Written contracts must include:
Processing subject matter and duration
Type of data
Obligations and rights of both parties
Duty of confidence
Security measures
Deletion/return at contract end
Assistance with SARs and FOIA
Compliance with GDPR
6.3 No data shall be transferred outside the EU without proper safeguards.
7. Data Requests
7.1 Subject Access Requests (SARs)
Individuals have a right to know and access personal data held about them.
7.2 SARs include data held by MCL and its processors.
7.3 SARs must be referred to the DPO.
7.4 SARs are free unless excessive.
7.5 MCL must respond within one calendar month.
7.6 FOIA Requests
7.7 MCL must maintain a publication scheme.
7.8 Business-as-usual requests need not follow FOIA if info is publicly accessible.
7.9 Non-public requests must be referred to the DPO.
8. Data Breaches
8.1 A breach includes loss, access, destruction or alteration of personal data.
8.2 All breaches must be reported to the DPO immediately.
8.3 The DPO shall assess and mitigate risks.
8.4 The DPO must report to the ICO within 72 hours if required.
8.5 All breaches must be logged, even if not reported.
9. Data Protection Impact Assessments (DPIAs)
9.1 DPIAs help identify risks in new or changing processing activities.
9.2 DPIAs are required for:
Automated profiling
Processing without notice
New sensitive data handling
Innovative technologies
Risk of physical harm
Location tracking
9.3 DPIAs should be considered for significant changes in processing.
9.4 DPIA contents must include:
Description of processing
Proportionality and minimisation checks
Stakeholder consultation
Risk mitigation
Contractual requirements
Ongoing compliance steps
DPO advice
9.5 All completed DPIAs must be logged.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including:
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it.
The Company has primary and day-to-day responsibility for:
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
Feedback and suggestions for improvement are encouraged and should be addressed to the Managing Director.
You must:
If you believe or suspect that a conflict with this policy has occurred or may occur in the future, you must notify your line manager or a company Director as soon as possible.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or may occur, notify your line manager, a company Director, or report it in accordance with our Whistleblowing Policy.
We will support and guide our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains, where appropriate.
If you are unsure whether a particular act, treatment of workers, or working conditions constitutes modern slavery, raise it with your line manager or a company Director.
We are committed to encouraging openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are also committed to ensuring no one suffers any detrimental treatment as a result of reporting suspected modern slavery.
Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered such treatment, inform your line manager immediately. If the matter is not remedied and you are an employee, raise it formally using our Grievance Procedure.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may also terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Paul Finder
Director
2021
Environmental Policy
Our Environmental Policy is to be a responsible corporate citizen in protecting the environment. We
are committed to complying with accepted environmental practices, including the commitment to
meet or exceed applicable legal and other requirements, to strive for continual improvement and to
minimise the creation of waste and pollution. We will, therefore, manage our processes, our
materials and our people in order to reduce the environmental impact on our work.
Millbeck Communications have set out the following main objectives:
• Reduce, reuse and recycle waste and packaging.
• Improve the efficiency of energy usage.
• Constantly review aspects, objectives and targets.
• Understand the requirements of customers, authorities and agencies.
Environmental Planning
The Company Environmental Policy forms the basis of Environmental Planning and the identification
of environmental impacts with the organisation. However, it is acknowledged that where
specifically requested by customers, and ascertained at contractual planning and agreement stage,
additional requirements may be produced as required.
Environmental Policy
To confirm our commitment the Company management has developed a policy statement
appropriate to our operations as described below. This policy enables us to work towards objectives
of sustainable environmental improvement, which will lead to the prevention of pollution and future
protection of the environment
Due to the nature of our Company business, i.e. service industry and not manufacturing industry, we
do not use toxic materials or substances in the carrying out of our business.
All employees are encouraged to understand and implement the objectives of this policy in their day
to day work through regular discussion, communication and training.
The Managing Director has specific responsibility for policy development, co-ordination and
evaluation. Millbeck Communications is committed to minimising the impact of its operations on
the environment by means of a programme of continual improvement.
In particular Millbeck Communications will:
a) Ensure appropriate resources will continually be made to ensure the environmental policy is
implemented in full.
b) Discuss environmental issues with all employees, conduct training programmes and encourage
best implementation practice by all Millbeck personnel.
c) Meet, and where appropriate, exceed the requirements of all relevant legislation.
d) Work with suppliers to minimise the impact of their operations on the environment through a
quality purchasing policy.
e) Seek to reduce the following:
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Consumption of materials in all operations, reuse rather than dispose wherever possible and to
promote recycled materials.
Ensure all our vehicles are replaced at economic intervals and regularly undergo normal servicing
where the key factor is the exhaust emission produced by these vehicles and also ensure they are
well below the limits set by the Department of Transport and where possible use hybrid or electric
vehicles.
Noise, visual and other impacts on the local environment.
Environment Policy
Regular review of environmental performance will be actioned to ensure our environmental
objectives and targets as described are maintained at all times.
Additionally this Environmental Policy Statement will be made available to all interested parties at all
times.
Environmental Management Review Meetings
Annually an Environmental Management Review Meeting is held by Managing Director and relevant
Company personnel.
The objectives of these meetings are primarily to:
Review the environmental management policy, to ensure its continuing suitability, adequacy and
effectiveness.
Ensure the requirements and objectives of the Company Environment Policy continue to be
maintained.
Sustain continuous improvement in overall environmental performances.
Ensure compliance to all applicable legislation and other requirements.
Millbeck Communications Complaints Procedure
Contents
1 Overview.
2 How to make a complaint
3 What to expect
4 How to escalate a complaint
5 Alternative Dispute Resolution Scheme
6 Contact Details
1 Overview
Millbeck Communications provides Internet of Things (IoT) connectivity solutions. Millbeck
Communications provides Machine-to-Machine Services; these are a service which allow for the
automated transfer of data and information between devices or software-based applications with
limited or no human interaction.
We recognise that things can go wrong and we have a complaints process in place to ensure we
handle such situations appropriately and in a timely manner.
This code sets out how you can make a complaint to us, what to expect from us if you do and what
you can do if the complaint is not handled to your satisfaction.
Please contact us if you require this information to be sent to you in large format or Braille.
2 How to make a complaint
Our Customer Services Department is there to handle all day-to-day service changes, fault repairs
and billing queries. If you have an issue that fall outside of this, or if you have already contacted
them and you do not feel you have received an appropriate level of support, you may make a
complaint by any of the following means:
In writing to our head office (see contact details below)
By calling our main line number 01937 534915 and stating that you wish to make a complaint.
By emailing to info@millbeckcomms.co.uk and stating clearly that you wish to make a complaint.
It will help us to investigate your complaint if you set out clearly the nature of the complaint and any
relevant history, including ticket references where appropriate.
3 What to expect
Our policy is to provide an initial response to complaints from the appropriate manager within one
working day of receipt. Thereafter the manager involved will be in contact on a regular basis as
agreed with you.
We aim to resolve all complaints to the satisfaction of our customers within two weeks.
4 How to escalate a complaint
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If you feel your complaint is not being handled to your satisfaction you can escalate the complaint to
a senior manager. The methods for doing this are as for the initial complaint: in writing, by phone or
by email stating that you wish your complaint to be escalated to senior management level.
5 Alternative Dispute Resolution Scheme
In some cases an impartial third party may be required to resolve a dispute. Millbeck
Communications is a member of the Ombudsman Services Scheme (OS). OS is an independent
dispute resolution service who can assist in resolving a dispute between a member company and
individual customers and business customers with ten employees or less. They will consider both
sides of the complaint and arrive at a decision. As an OS member we are bound by that decision,
however you are always entitled to reject it and pursue other avenues.
In order to refer a complaint to OS, please use the Ombudsman Services Website .
6 Contact Details
Our head office Millbeck Communications Limited, 6 Arena Park, Tarn Lane, Leeds, LS17 9BF – 01937
534915
Our support team 01937 534915 info@milbeckcomms.co.uk
Our Alternative Dispute Resolution Scheme The Ombudsman Service Ltd The Brew House
Wilderspool Park Greenall’s Avenue Warrington WA4 6HL www.ombudsman-services.org
UK Telecoms Regulator Office Of Communications (Ofcom) Riverside House 2a Southwark Bridge
Road London SE1 9HA 0300 123 3333 www.ofcom.org.uk
