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What information do we collect about you?
The only information we hold about you is the information you provide (see below table for what information this might include) and our own records about services we have delivered. The only information our website automatically records is users’ IP address. These IP addresses are not linked to any personal data and visitors to our website remain anonymous.
How will we use your information?
We only use your information for the purposes for which it was intended. As defined by the Information Commissioner’s Office (ICO), the lawful basis for processing your information is when:
- Consent of the data subject is given;
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract;
- Processing is necessary for compliance with a legal obligation;
- Processing is necessary to protect the vital interests of a data subject or another person;
- 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;
- Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
The following table outlines how your information will be used and if it will be shared with anyone. Information is only shared for the purposes for which it is intended and on a need to know basis.
If you are not included in any of the above categories and would like to know more about what we do with your data, please contact the Data Protection Officer who will advise (contact details below).
How do we store your information?
We store all your information securely, we restrict access to only those who need it and we train our staff in handling information securely. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
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.
Your information will only be retained for as long as necessary. Your information will normally be deleted or destroyed within 3 years after the end of your relationship with us, or 7 years in the case of financial records. The data retention periods are set out in our Document Retention Policy, which our staff are required to adhere to.
We will not pass your information on to a third party for marketing purposes. Whenever we collect information which may be used for marketing, we will inform you and you will have the opportunity to opt in. At any time, you have the right to stop us from contacting you for marketing purposes; you can do this by email or post (see contact details below).
Access to your information
You have the right to request a copy of the information that we hold about you. To request this information you can email firstname.lastname@example.org or write to the Data Protection Officer at the address below. You can make a request using our standard form – please click here to access. You are not obliged to use this form to make a request, but doing so will make it quicker and easier for us to respond.
We will require proof of your identity before the information can be given. There is no charge for this service. We aim to reply as promptly as possible within one month of the request. Some more complicated requests may take longer; you will be advised if this is the case. Requests which are unfounded, excessive or unreasonable may be refused and you will be advised if this is the case.
We want to make sure that your personal information is accurate and up to date. As well as the right to request access to your information, you also have the right to:
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Professional advisers including lawyers, bankers, auditors and insurers based in THE United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based [in the United Kingdom who require reporting of processing activities in certain circumstances.
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.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How to complain about our handling of your information
If you are not happy with the way we have handled your information, you have the right to complain to the Information Commissioner’s Office (ICO). Information about how to make a complaint can be found at www.ico.org.uk.
Changes to our policy
Telephone: 028 9023 2020
Post: Data Protection Officer
239 Newtownards Road
BT4 1 AF
ICO Registration Number: ZA268924