DATA PRIVACY NOTICE
This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data, and keep it safe.
- WHO WE ARE AND WHAT WE DO
Ease Training Limited provides training and consultancy to charities and schools on many aspects of governance.
- THE FIRST POINT OF CONTACT FOR DATA PROTECTION(include Data Protection Officer here if you have one)
If you have any concerns or queries about our data protection procedures please contact Richard Levinge: Thursday Cottage, Ewen, Cirencester GL7 6BU Phone:01285 770984
- WHY WE PROCESS DATA
We process data for a variety of reasons:
- to let people know about events, training and all of our consultancy work
- to organise and delivery training, events and consultancy services
- we process some limited data to promote and share new ideas and good practice in education and charities – for example through GovernorHub – an interactive resource designed specifically for school governors
- to engage with leading experts in a variety of roles connected to Ease Training
- to be able to invoice for our work and pay our suppliers
- LEGAL BASES FOR PROCESSING YOUR DATA INCLUDING ANY EXPLANATION OF LEGITIMATE INTERESTS
The law on data protection sets out a number of different reasons for which a business may collect and process your personal data. Some of these reasons, set out below, are the bases we have for processing your personal data:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters or where you have asked us to keep you updated with our work.
Occasionally we contact organisations and businesses about our services where they have given explicit consent to other connected organisations for us to provide them with relevant information.
When collecting your personal data, we always make clear to you which data is necessary in connection with a particular service.
In order to deliver some of our training and events we may need to process special category data that you supply to us (for example any disability or health issues). We only do this with your explicit consent
In certain circumstances, we need your personal data to comply with our contractual obligations.
We need to collect and retain your contact details so we can for example:
- deliver our services, training and events
- to enter into contract with you to supply us with goods or services
If the law requires us to, we may need to collect and process your data.
For example we are obliged to retain certain information for HMRC reporting purposes or to comply with other legislative provisions
In particular circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we retain customer, client and supplier information for 10 years beyond our contracts in order to maintain good working relationship with these individuals and organisations.
We also undertake relevant marketing by electronic means to business contacts and other organisations and individuals to whom we have delivered training or consultancy services.
- WHEN WE COLLECT DATA
- If you fill in our contact forms – the information such as your name and email address is processed by us
- When you make an enquiry either on line or by telephone we process your information in order to be able to answer your query
- when you book onto one of our courses or events we will need to collect your name, contact details, and dietary requirements.
- when you pay us for our services or we pay our suppliers we collect limited financial information
- we collect information from our associates and others with whom we deliver our services in order be able to display their information on our website and other promotional information
- WHAT DATA WE COLLECT
- Information from the website …. details: IP address, info from cookies
- Contact information including: name, address, phone number, email address
- Bank details – to process payments or invoices
- In some circumstances we collect and process more personal details such as dietary requirements and health / disability issues which enables us safely to deliver training and events and gives our participants the best possible experience when interacting with us.
- For our associates and other experts we also process more detailed information such as qualifications and experience
- HOW WE USE YOUR PERSONAL DATA
We process data for a variety of reasons. Each of these relate to the running of the business and giving our customers or clients the best experience possible.
- to make sure our website gives the best possible experience for anyone using it
- to assist in answering questions you may have
- to allow booking of training and events
- to communicate with everyone about events and training and our services which are of interest to them
- to process payments
- to fulfil all contractual and legal obligations
- HOW LONG WE KEEP YOUR PERSONAL DATA
Whenever we collect or process your personal data, we only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will be deleted completely
Some examples of our data retention periods:
We retain all client and supplier information for 10 years beyond the contract period in order to be able to maintain the best working relationships with everyone we interact with.
We are also obliged to retain certain transactional information for 7 years to satisfy accounting rules
- HOW WE KEEP YOUR DATA SAFE
We are aware of the need to maintain the correct and highest level security when processing your personal information. We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.
We take the following steps to maintain the security of your personal information:
- we keep all of your information in systems that are secure,
- We limit access to your personal information to those who have a genuine business need to know it.
- we have password protected systems
- we maintain firewalls and anti-virus software
- any data which is accessed off site or on a mobile device is password protected
- Insurance approved locks protect any documentation retained in paper form or kept in our offices.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- WHO WE SHARE YOUR DATA WITH
We sometimes share your personal data with trusted third parties which act only on our instruction (known as “data processors”).
Data processors might be, for example, our 3rd party accounting apps or cloud providers such as Microsoft who store data for us:
Where we share information with these companies or individuals we make sure that they also keep your data secure and that they also protect your rights. To this end we make sure that:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them or where their terms and conditions of processing contain the correct data processor clauses under GDPR
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Sharing your data with third parties for their own purposes (“joint controllers”) eg HMRC, accountants, legal advisors or our associates and experts
We will only do this in very specific circumstances, for example:
- With your consent
- Where we have a data sharing agreement in place with the other party
- Where we are obliged to share the information for legal reasons
- WHERE YOUR DATA IS PROCESSED
We do not transfer data outside of the EEA. Our servers are located in the UK.
From time to time we may pass personal data such as your name and email address to other services that we use to send out newsletters and other communications (both electronic and print).
However, your personal data will remain in the EU or countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. Companies based in the USA that have certified with the EU-US Privacy Shield programme are also considered to be permitted destinations by the EU (this includes popular US products like Gmail, DropBox and MailChimp).
- YOUR RIGHTS AND WHO TO CONTACT
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of those rights, please contact us by emailing:
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. You can do this by contacting
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We will then stop processing your information unless we believe we have a legitimate overriding reason to continue processing.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request. To ask us to stop direct marketing please contact:firstname.lastname@example.org
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
For us to check your identity please:
- let us have enough information to identify you [(eg your full name, address and client or matter reference number)];
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to contact the ICO
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence
You also have the right to take to seek a judicial remedy.