GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
JCML Consultancy Ltd (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
JCML Consultancy Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: JCML Consultancy Ltd T/A GreenFish Consulting, 177 Silverdale Road, Tunbridge Wells, Kent, TN4 9HT, Telephone: 01892 300450, Email Address : firstname.lastname@example.org . For all data matters contact Daniel Smith on email@example.com
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To aid our performance of a contract with you
- Providing and managing your account
- To carry out obligations arising from any contracts entered between you and us and to provide you with information, products and services that you request from us.
- Market research
- To allow you to participate in interactive features of our service
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience
- With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, or post with information, news and offers on our products and services.
- What data do we collect?
Depending upon your use of our site, we may collect some or all of the following personal and non-personal data;
- Name, email address, address and telephone number
- Demographic information such as email addresses and telephone numbers
- IP Address
- Web browser type, version and operating system
What are cookies?
Cookies are small files saved to the user’s computers hard drive that tract, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features.
Should users wish to deny the use and saving of cookies from this website onto their computer’s hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.
- Sharing your personal data
Your personal data will be treated strictly confidential and will be protected from unauthorised or accidental disclose. We may only share your personal data in the following circumstances:
- We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, and delivery of goods support services. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data is handled safely, securely, and in accordance with your rights, our obligations and the obligations of the third party under the law.
- In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, a court order, or a government authority.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 10 years in order to complete ongoing projects, in case of any legal claims/complaints, audit purposes, and training purposes. Unless your permission is revoked, in which case, your data will be removed.
- Providing us with your personal data
We require your personal data as it is a contractual requirement, or a requirement necessary to enter into a contract.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, 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 YOUR LAWFUL BASIS FOR PROCESSING THE 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 i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the 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 the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
We do not transfer personal data outside the EEA.
- Storing your data
We take every step to secure and protect your data, which include:
- Strict access limitation and logging onto our physical internal servers
- Server side encryption of personal information
- Limited and heavily monitored access to our front end systems.
- Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Daniel Smith on 01892 300370.
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 at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.