Thank you for trusting us with some information about you. We take that trust seriously and we want you to know how we use your information and why.
Last Updated: 23rd Aug 2021
WHOSE INFORMATION DO I COLLECT?
I process information about:
- "Prospects" contacts working at or connected with potential Clients;
- "Clients" who have bought goods or services from me, and "Client Contacts" who are individuals employed by or contracted to Clients;
- "Employees" My employees if I have any. Employees should refer for data privacy information relating to their own data to their contract of employment.
I promise respectful treatment of the personal information of everyone I have contact with. I want it to be simple and clear.
This Policy explains how I do that – when and why I collect information, how I use it, the situations when other people can see or use it, and how I keep it secure.
But just to set the scene in case you don’t want to read through all the details just now, I can be clear up front.
I don’t sell, rent or trade email lists with anyone else.
I've split this Policy into sections, depending on who you are.
- Section A is for everyone and includes information about cookies on my website.
- Section B is for you if you are or work for a business prospect.
- If you are a Client or a Client Contact, Section C is for you.
- Section D is for you if I have information about you purely because I am providing services to a Client.
Whoever you are, my intention is to use your information to make things work smoothly for you in your experience of dealing with me. If that’s not how it turns out for you, please make sure to contact me. It’s best to put things in writing, which you can do by emailing the address above.
I keep this Policy under regular review, and I may revise it as time goes on. Please check back here from time to time to make sure you’ve got the latest information.
MY GENERAL APPROACH TO PERSONAL DATA
I'm committed to protecting your privacy and honouring your legal rights to control how I use your personal data.
I only collect and use personal data when I need to because you have asked me to do something (for example, send you newsletters);
- so that I can reply to queries or complaints;
- to develop and manage my business relationships;
- to help grow my business and fulfil my contracts;
- to provide services to clients;
- to meet my legal obligations.
I try to make sure the information I hold is accurate and up to date and is no more than I need to have.
CATEGORIES OF DATA
The types of information that I will be processing depend on the nature of my relationship with you.
I may process information about you that you have yourself provided to me or published generally on the internet through social media or on other websites.
In all cases, I will have what identifying and communication information that is relevant and that I can sensibly obtain: that is, your name, email address, employer or business name, job title or position, contact address, social media addresses, and I may also capture some of the information published by you in your social media output to the extent that it may be relevant to my interactions.
If you are or work for a prospect, I will aim to obtain and process information that is relevant to myself building a business relationship with you and doing business together, which may relate to your business and your personal interests.
If you are or work for a customer or supplier, I will also keep records of our interactions, the work I have done for you or commissioned from you, the progress of work, and financial and accounting records.
If I am processing information about you purely because I am providing services to others, please see Section D below. Please note that your rights may be subject to applicable exemptions.
If you have any questions or concerns about my use of your information, or how I have responded to any request about your personal data, please take it up in the first instance by emailing me at firstname.lastname@example.org.
DOWNLOADS, NEWSLETTERS AND SERVICES
I monitor who opens what in my newsletter lists, and pre-set sequences of information I send you. I do this, so I can see if content is popular and generate more of it, or if it is not read.
There may be sub-routines that trigger if you click on links or articles. These are designed to offer you more information about things you are interested in.
You can unsubscribe from these sequences at any time.
Existing Clients may receive emails about specific offers relating to things you have already purchased. You can unsubscribe from these at any time.
I use automations (little sequences of emails that start when you ask for something in particular) to send you the information you asked for, to send you products you have bought and to administer services you have subscribed to. A lot of my onboarding for new products is by emails that send you hints and tips and little videos on ‘how to’. You can unsubscribe from these at any time, but they don’t go on for that long and you might want to wait for all the information as most people find it useful.
I monitor who reads my mailing and automations, how many times, and which links you choose to use and read. I use this information to increase the content’s level of interest and help me improve what I send. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails from me. From time to time, I contact individual email newsletter subscribers, but it is extremely rare.
I use anonymised data about you from time to time to target advertising campaigns based on profiling the sort of person who wants to receive information from me.
I ask my own sales and marketing people (both internal and external) to contact Prospects from time to time. This is normally because you have requested a call, or because I am actively trying to let you know about something you may benefit from.
I am not a hard sell or cold calling based organisation but prefer to build long-term relationships with satisfied and relaxed clients.
If you ‘like’ any of my posts or ‘follow’ me or contact me on social media I keep a record of that.
NO SALE OR EXCHANGE OF YOUR DATA
I do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
DATA LOCATION AND PLATFORMS
Like most small businesses, I do not have any tailor-made software – I use mainstream packages for everything from my Client records, to email, to accounting.
This means that some of your data may be held in the EEA, and some may be held in services in the USA (with suitable data privacy shields) or elsewhere. I have picked mainstream suppliers with appropriate security standards.
HOW LONG DO I KEEP YOUR DATA FOR?
Your information will be kept for the length of time set out in my retention period (see Section 1, Table, above).
If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.
WHAT ARE YOUR RIGHTS
You have the right to know what information I am collecting on you, and to amend it if it is inaccurate.
If you feel for some reason I have information I should not be keeping, or it is out of date or otherwise wrong, please let me know and I will take appropriate action.
Most of the information I hold is not based on your individual consent but is based on myself needing the information to run my business and provide my products and services.
You have a "right to be forgotten" - but that does have some legal limits to it. If you want me to remove information about you, let me know. If you have been a Client, I may not be able to remove all data as I will have to ensure that I can continue to comply with legal, accounting, taxation and my insurer’s requirements.
OUR LEGAL BASIS FOR PROCESSING YOUR DATA
Signing onto my newsletter list is by your consent – and when you withdraw your consent I stop that processing of your data.
Apart from that, the information I hold is based on myself needing the information to run my business and provide my products and services – either so I can perform my contract with you, or because I have a legitimate business interest in processing your data.
In a few situations I am processing personal data because I am under a legal obligation to do so. This principally relates to my business, accounting and tax records.
Most of the information I process comes from you. I process it so I can reply to you, and when you contact me again I know what you asked before, what you were sent, and what you told me.
Typically, I am collecting name, contact details, how I came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in my products or services or a relevant contact for my business.
If you sign up to a newsletter list, you will be sent what you asked for. You can unsubscribe at any time by clicking the unsubscribe button on any email.
You are not automatically subscribed to any other lists but may be invited to join an appropriate one.
If I email you individually using my own email system or respond to an email sent to me at any of my business email addresses, a copy of that email will also be stored.
If you make an enquiry via my website, I will keep details of that enquiry and response for my data retention period (Section 1, Table, above).
I do not routinely keep special category data. To the extent I hold this, it was supplied or made publicly available by you.
Once you buy something from me, I will collect information from you at the point of sale.
This will include the information I collect from Prospects (above). I collect your email address, phone number and postal address so I can provide what I have contracted to, invoice you and keep proper records of our business relationship.
I process your data to support the delivery the goods and services you have bought. I keep records of the goods/services provided to you, and information you give me, so I can support you when needed and advise you of any additional services you may need.
THIRD PARTY DATA
As well as your own personal data, I understand that you may need to provide me with personal data relating to your employees, your workers, or third parties (often your clients or suppliers) – depending on the services I am providing to you. I hold all such information under strict confidentiality obligations, as set out in my terms of business.
I will act in accordance with your statutory rights, subject to the exclusions and exemptions that may apply.
When I am processing data about you because of a direct connection between you and my business I am acting as a ‘data controller’ (and operating under this policy).