Privacy

Phonehub IO Ltd is a company registered in England and Wales, company number 9568821 with the registered office / postal address: 1-2, The Old Church, St. Matthews Road, Norwich NR1 1SP, United Kingdom.

This privacy policy will explain how our organization uses the personal data we collect from you when you use our service: Prison Video – Secure Video Calls System.

Links to other websites

Our website may contain embedded content and links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over the linked site. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting linked sites. You should exercise caution and look at the corresponding data protection or privacy statement applicable to the website in question.

What data do we collect?

Phonehub IO Ltd collects the following data:

Prisoner

Name (First and Last Name)
Prisoner Number (Unique Identifier of the prisoner)
Notes (Any extra information concerning the prisoner is added here) for example details of any special circumstances or family situation which other staff should be aware of.
Restrictions (Restrictions that must imposed on the Prisoner if they are to use the service)
Biometric data

Staff

Name (First Name and Last Name)
Email Address
Role

Social Contacts

Name (First Name and Last Name)
Date of birth
Email Address
Phone Number
- Phone Country (This is determined from the phone number but this can be changed as well)
- Location
Address Details
- Address Line 1
- Address Line 2
- City
- County / State
- Country
- Postcode
Photo of ID document
Face photo
Biometric data
Device metadata

Social contacts (children) and other sub-accounts

Name (First Name and Last Name)
Date of birth
Relationship to primary account
Photo of ID document (may not be required for under 18s)
Face photo
Biometric data

We process your personal data in line with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). The legal basis for processing your personal data is generally:

processing is necessary for compliance with a legal obligation to which the controller is subject; or
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Processing is necessary for the performance of a task carried out for a law enforcement purpose by a competent authority.

If the data is a special category of personal data then the legal basis is generally:

processing is necessary for reasons of substantial public interest and for the exercise of a function conferred on a person by an enactment or rule of law with regards to the administration of justice.
In certain circumstances there may be other legal bases for processing your data. Please refer to the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and The Prison Rules 1999.
In the majority of circumstances we do not require your permission to process your personal data. However where any processing of your personal data is based upon consent you may withdraw that consent at any time.

How do we collect your data?

You directly provide Phonehub IO Ltd with most of the data we collect. We collect data and process data when you:

Register online via the mobile app.
Are registered by somebody else via the mobile app.
Use our services.
Contact us via email, telephone, or by other means.
Use or view our website.
Use or view our apps.

Phonehub IO Ltd may also receive your data from the following sources:

From prison staff.
From prisoners requesting to contact you.
From external contacts who are adding other participants to their account.

How will we use your data?

Phonehub IO Ltd collects your data for the purpose of:

Identification of video call participants

The nature of the prison environment means there are security and public protection risks of all communications between prisoners and the outside world. The prison has processes designed to mitigate these risks, but these require certainty of the identities of the parties on the call to be effective. The Prison Video system therefore uses a variety of data points to identify and verify the identity of the parties on the call.

Prevention of system misuse or abuse

The system collects and analyses a range of data points to protect against misuse of the system and breaches of the terms of use by participants, and to reduce the burden on monitoring staff by automatically flagging potential issues.

Communication with staff and call participants

One of the main challenges of prison telecommunications systems is organising call times that suit the external participant, the prisoner, and the prison regime. Contact information for external parties and staff, and location information for the prisoner, enables all parties to be notified about call times.

Intelligence and law enforcement

Communications footage must be retained in line with Prison Service policy for the management of Prisoner Communications. It is recorded in case it needs to be retained for evidential purposes due to public protection breaches, or other criminal activity.

Automated decisions

In certain situations an automated system may be used to make judgements about activity within calls or biometric comparisons. All such decisions are subject to oversight by a human operator.

Phonehub IO Ltd will not share your data with any third parties with the exception of:

HMPPS
UK Ministry of Justice
Operators of prisons which offer the service (for example Sodexo)

Phonehub IO Ltd will never provide your information to any other organisation for direct marketing purposes. We will not distribute, sell or lease your personal information to third parties unless we have your permission or are required by law to do so.

If you have paid for the service via a credit or debit card, your card details are stored by a valid third party payment provider (PayPal) in order to conform to PCI requirements. User details may also be passed on to our payment provider for fraud prevention purposes.

Other third parties may be used strictly for the purpose of providing the service (such as for sending text notifications). They may be international organisations, outside the United Kingdom.

How do we store your data?

We will retain user data throughout the period of providing you with the service. Phonehub IO Ltd securely stores your data in line with standard data protection practices.

We only retain personal data for as long as is necessary. The timeframes differ depending on the type of personal data being processed and the retention and destruction policies specified by Ministry of Justice.

What are your data protection rights?

Phonehub IO Ltd would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Phonehub IO Ltd for copies of your personal data.
The right to rectification – You have the right to request that Phonehub IO Ltd correct any information you believe is inaccurate. You also have the right to request Phonehub IO Ltd to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Phonehub IO Ltd erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Phonehub IO Ltd restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Phonehub IO Ltd's processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Phonehub IO Ltd transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to decision review You have a right to request any automated decision be reviewed by a human operator.

We may charge an administration fee for repeated or excessive requests. In addition, it may not be possible to continue offering the service (or it may be temporarily suspended) after personal data is modified.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:

Call us at: 01666 333760
Or email us: info@phonehub.io

Or write to our Information Security Manager/Data Protection Officer at:

Information Security Manager
Phonehub IO Ltd
1-2, The Old Church
St. Matthews Road
Norwich NR1 1SP
United Kingdom

You have the right to lodge a complaint with a supervisory authority if you believe your information is not handled according to regulation.

In the UK you can complain to the Information Commissioner's Office:

Using their live chat service ico.org.uk/livechat, or calling their helpline on 0303 123 1113.

By writing to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF.

Cookies

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By default, most browsers will accept cookies. In the event that you wish to disable all cookies, including essential cookies, please modify your browser settings to decline and remove the cookies. This will prevent you from using the website as intended.

Changes to our privacy policy

Phonehub IO Ltd keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 18th October 2021.

How to contact us

If you have any questions about Phonehub IO Ltd's privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@phonehub.io

Call us: 01666 333760

Or write to us at: Phonehub IO Ltd, 1-2, The Old Church, St. Matthews Road, Norwich, NR1 1SP