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HOW YOUR DATA WILL BE USED
2.1. We use information held about you to:
2.2.1 carry out our obligations arising from any contracts entered into between you and us and provide our services
2.2.2; carry out feedback and research on our services; and
2.2.3 notify you about changes to our services
2.3 We never sell your data to third parties.
2.4 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out below (please also see paragraph 9.6 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.
LAWFUL BASIS FOR PROCESSING
2.5.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
2.5.2 Consent – Where possible, we will seek to obtain your consent to process your data outside our contractual obligations (see above).
2.5.3 Contractual – Where processing is necessary for the performance of a contract with you.
2.5.4 Legal obligation – Where processing is necessary to comply with the law (e.g. safeguarding).
THIRD PARTIES AND SHARING INFORMATION
3.1.1 We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.
We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
3.2.2 Please see below the list which sets out the categories of recipients of personal data.
SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA
IT Support Services
Secure document disposal service
Banks and Accountants
Online payment providers
3.3.3 In addition third parties may provide us with personal data and they should only do so where the law allows them to.
WHERE YOUR DATA IS HELD
4. Your data is stored by us and our processors in the UK, EEA or in a country where an adequacy decision has been made by the European Data Protection Board (EDPB). Where we transfer your personal data outside of the EEA, we will ensure that all appropriate technological and organisational measures are in place to provide your data with the levels of protection as required under the Data Protection Laws.
5 Our data retention policy is dictated by the Data Protection Laws and is available for inspection by submitting a written request using the contact details provided in this policy.
6.1 Under the Data Protection Laws your rights are:
6.2 Access – You are entitled to find out what details we may hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their Personal Data by making a formal request under the Data Protection Laws. Such requests should be in writing to the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will:
(a) confirm that your data is being processed;
(b) verify the lawfulness and the purpose of the processing;
(c) confirm the categories of personal data being processed;
(d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
(e) let you have a copy of the data in format we deem suitable or as reasonably required by you.
6.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
6.4 Erasure – This is also known as the request to be forgotten. Under Data Protection Laws you have the right to erasure under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
6.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
6.6 Portability – You have the right to obtain and reuse your personal data that you have provided to us.
6.7 Object – You have the right to object to us processing your data in relation to direct marketing and or profiling.
6.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
6.9 Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the Data Protection Laws and as summarised above.
7. You have the right to complain about the processing of your personal data. Please contact us using the details provided above. If you are still unsatisfied you have the right to complain to the Information Commissioners Office.