Privacy Policy

The data I collect about you and how I collect it

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified.

How I use your personal data

I will only use your personal data when the law allows me to and for the purposes set out in this Policy.

These are:

• When you give your consent
• When necessary to comply with a legal or regulatory obligation
• For my legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not override those interests.

Purposes for which I will use your personal data

I have set out below a description of the ways I may use your personal data:

• I process personal data lawfully, fairly and in a transparent manner.
• I collect personal data only for specified, explicit and legitimate purposes.
• I process personal data only where it is relevant, and I limit the data to what is necessary for the purposes of processing.
• I keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• I keep personal data only for the period necessary for processing.
• I adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
• I explain the reasons for processing your personal data, how I use such data and the legal basis for processing in my privacy notices. I do not process personal data of individuals for other reasons.
• I will update personal data promptly if you advise me that your information has changed or is inaccurate.
• I keep a record of our processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I 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 me using the details set out above.

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so. I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Storage

I will only retain your personal data for as long as necessary to fulfil the purposes for which I collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

I will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Policy.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

Marketing Communications

I may use your personal data to form a view on what I think you may want or need, or what may be of interest to you.

You will receive marketing communications if you have requested information or services from me and you have opted in to receiving marketing communications.

You can ask me or third parties to stop sending you marketing messages by contacting me at any time.

Data Security

I 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, I 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 my instructions and they are subject to a duty of confidentiality. I 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 I am legally required to do so.

Your Legal Rights

Under data protection law you have the following rights in respect of your personal data:

• to request information regarding the personal data that I hold about you and the source(s) of that information. You can request a copy of any personal data I hold about you. This service is usually free of charge, although I have the right to charge a ‘reasonable fee’ in some circumstances;
• to request that I rectify any inaccuracies in relation to the personal data I hold;
• in some circumstances, to request the erasure of your personal data or object to the processing of your data;
  to object to any direct marketing;
• in some circumstances, to request that your personal data be transferred to you or a new provider if the data is processed automatically;
• to withdraw consent to me processing your personal data. This will not affect the processing already carried out with your consent; and
• to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office. I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
• If you wish to exercise any of the rights set out above, please contact me using the details set out in this policy.
• What I may need from you
  • I may need to request specific information from you to help me 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 a person who does not have the right to receive it.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.