DATA PRIVACY POLICY
1 INTRODUCTION
We respect your privacy and are determined to protect your personal data. We promise to:
- Keep your data safe and private
- Not to sell your data
- Give you ways to manage and review your marketing choices at any time
- Hold your data securely in accordance with our internal security policy and the law.
In these paragraphs we tell you more about our policy on how we look after your personal data when you visit our website (regardless of where you visit it from), sign up to our email list, purchase a product or service, take part in a competition or otherwise engage with us. We also tell you about your privacy rights and how the data protection law protects you.
It is important that you read these paragraphs on our privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
2 OUR ROLE IN PROTECTING YOUR DATA
Our company is called Helen Harding Ltd. We are registered in England and Wales under company number 8718733 and have our registered office and main trading address at White House, Aberedw, Builth Wells, Powys LD2 3UW.
Under data protection law, Helen Harding Ltd is designated as a Data Controller and is responsible for how we use your personal data when you engage with us.
If you have any questions or concerns about how we manage your personal data please email our Director, Helen Harding, who oversees our approach to data protection: [email protected]
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3 THE PERSONAL DATA WE USE
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner’s Office.
You provide us with personal data when you:
- Create an account on our website
- Make an enquiry of us
- Apply to one of our courses/sessions or consultancy services
- Buy a product from us
- Attend one of our courses or sessions
- Sign up to a newsletter or subscribe to a service or publication
- Engage with us in one of our interactive services or on social media
- Agree to take part in research
- Request marketing to be sent to you
- Provide us with services.
We use the term ‘use’ to refer to our activity of collecting, using, storing and transferring different kinds of personal data in connection with the above. We have grouped together the different kinds of data we use as follows:
- Identity Data includes first name, last name, username.
- Contact Data includes billing address, email address, telephone numbers.
- Profile Data – includes information relevant to providing our services. Given the services we deliver it is possible that you may on occasion provide us with what is known as Special Categories of Personal Data about you (this includes details about your health and genetic and biometric data, your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,) and criminal convictions and offences. We also collect data on age to ensure we have appropriate consents.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity (this is by no far a comprehensive list). This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
4 PRIVACY WHEN YOU USE OF OUR WEBSITE
This paragraph sets out the terms on which we process any personal data we collect from you, or that you provide to us when using our website: www.helenharding.co.uk
By using our site or accessing any content or any of our services, you consent to such processing and you warrant that all data provided by you is accurate.
If you register on our site as either a guest or a registered user, the information you submit is used only to provide information and services that you have requested. We do not pass on your details to anyone else unless required to do so by law.
Please note our website is not intended for children and we do not knowingly use data relating to children via our website (although we may use data relating to age in the performance of our services – see below).
For more on the terms of use of our website click here:
5 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6 HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. The law allows us to use your personal information only if we have a justifiable reason to do so.
Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us: Helen Harding, [email protected]
7 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us: Helen Harding, [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer or client |
(a) Identity (b) Contact (c) Marketing and Communications |
Performance of a contract with you and for accounting purposes. |
|
Newsletters or similar subscription services |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Performance of a contract with you and legitimate interest To provide tools and tips to help you To provide further information about developments within our services |
|
To deliver services to you |
(a) Identity (b) Contact (c) Profile (d) Financial (e) Transactional
|
Performance of a contract with you and legitimate interest To ensure we deliver in an appropriate manner recognising your needs to meet your best interest and provide support |
|
Client notes |
(a) Identity (b) Contact (c) Profile (d) Transactional |
Performance of a contract with you and legitimate interest To keep an updated record of our work together. To respond to questions or complaints and demonstrate our fair treatment of you. |
|
Marketing |
(a) Identity (b) Contact (c) Transactional (d) Marketing and Communications |
Legitimate interest To keep you informed of latest news, articles, events, products and services. To make relevant offers to you. |
|
Professional Supervision |
(a) Identity (b) Contact (c) Profile (e) Transactional |
Performance of a contract with you and legitimate interest Ensure quality of service Meet your best interests and support |
8 MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
8.1 Promotional offers from us
We may use your Identity, Contact, Transactional, Usage, Marketing and Communications and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us when you purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
Our email marketing campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity (this is by no far a comprehensive list). This information is used to refine future email campaigns.
8.2 Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing [email protected] at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchased, product or service experience or other transactions.
9 CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Helen Harding, [email protected]
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10 WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 7 above.
10.1 External Third Parties Service
- Providers acting as processors based in the UK and Europe, who provide IT and website services.
- Professional advisers acting as processors or joint controllers including accountants, lawyers, bankers and insurers based in the UK who provide accounting, legal, banking and insurance services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Providers acting as processors based in the USA, who provide email services
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- In relation to Lightning Process clients, the Phil Parker Training Institute for contractual and supervisory reasons.
Other than those listed above, we share your information only with those you have given us permission to contact, (unless required to by law for the purpose of safeguarding yourself or others).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10.2 International Transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:
All suppliers have a Data Processing Agreement that meets GDPR requirements and are or have filed for Privacy Shield Certification
Please contact us: Helen Harding, [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
11 DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12 DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, Transaction and Profile Data) for seven years after they cease being customers for legal and tax purposes. All data will be stored securely and in line with legal requirements. In relation to clinical clients, we will store your clinical information for a maximum of 7 years after our last contact with you.
Enquiries and applications that you make and then do not choose to follow up on will be stored for 12 months. You may request these to be destroyed ahead of this timescale.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
13 YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact: Helen Harding, [email protected]
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you believe the information held by us, about you, is wrong or incomplete please contact us. We will take reasonable steps to check its accuracy and correct it.
14 CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGE
This version of our data protection policy was last updated on 31 January 2021 and historic versions can be obtained by contacting us: [email protected]
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
15 QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Helen Harding, [email protected].
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
