At DPAS we’re committed to protecting, respecting your privacy and being transparent in everything we do.
This notice explains:
- Who we are
- When we collect your information from you
- What type of personal information is collected from you
- How we use your information
- How long we hold your information
- The situations where we may share your personal information
- Controlling your personal information for marketing
- Your data rights
- Keeping your information safe
- Keeping children safe
- Links to other websites
We may change this policy from time to time so please check this page to ensure that you’re happy with any changes.
Any questions regarding our privacy practices should be sent by email to:
Nigel Gooding, DPO, 10 Oaktree Place, Exeter, EX2 8WA or firstname.lastname@example.org.
Questions for the DPO should be sent to DPO@dataprivacyadvisory.com
who are we
In this notice, all references to “DPAS”, “we”, “our” and “us” are to be taken as references to Gooding&Co Ltd, trading under the name the ‘Data Privacy Advisory Service’.
DPAS’s registration with the Information Commissioners Office as a Data Controller is number ZA283976.
We provide Data Protection Officer Services in accordance with Articles 37 to 39 of the General Data Protection Regulation (GDPR). We also provide Consultancy Services and Training in the field of Data Protection more generally.
We promise at DPAS that your personal data shall be:
- processed lawfully, fairly and in a transparent manner;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
When do we collect information from you?
We collect personal information in the course of our business. The main prompts for our data collection is when:
- You contact us in our capacity as a Data Protection Officer (DPO) for one of our clients
- You email us or call us to enquire about our products and services or submit an online form getting in touch or asking for our online materials
- We have been asked to contact you in relation to our business activity (i.e. your manager has asked us to speak to you about a service we provide or someone in your network has made an introduction)
- You apply for a job with us
- You use our website (i.e. IP address in Google analytics)
- You attend one of our training courses
- We become business associates/connections
What type of information is collected from you?
The information we collect will change based on the reason we are processing your data. We will never collect more from you than we need.
Data Protection Officer
When you contact us in our capacity as DPO, we will collect whatever information is necessary to fulfil our legal obligation to you and our contract with our client.
This will typically include your name and some details about why our client was processing your data and information about whether you feel they are meeting their data privacy obligations towards you. We may ask for verification to prove who you are and what your relationship is with our client.
You have the right to contact us in regard to all issues related to processing of your personal data. This includes contacting us to exercise your rights under the GDPR. We are bound by confidentiality in the performance of this task, in accordance with the Data Protection Act 2018.
You can contact our Chief DPO, Nigel Gooding, to find out more about how we process your personal data in confidentiality, by emailing email@example.com.
Enquiring about our products and services or asking for our materials online
When you contact us enquiring about our products and services, we will collect whatever information is necessary prior to taking steps to enter into a contract with you.
This information will typically include the name and place of work of key contacts in your organisation and their contact details. We will also process any information you submit via our online forms. We may also process any other information that we have legitimately collected about you in relation to our other services (such as whether your business has paid for our training courses in the past) where this other purpose was known to you at the point of data collection. This information would only be processed in relation to engaging in a contract at your request.
Contacting you after a referral
When we contact you at the request of someone else, we will always tell you who we are and where we got your information from. We will do this as soon as is reasonably possible and no later than 28 days after first receiving your contact details. Wherever possible, we will ask the person referring you to us to make the introduction or to check with you whether it is ok for us to call you first.
The information that we will have processed prior to that point will be likely minimal and will include your name, job title/ place of work and a contact point such as an email or telephone number.
The lawful basis we rely on when contacting you about our products or services at the request of someone else will be different depending on the context. For the most part, it will be in our legitimate interest to do so and you can request that we stop processing your data. Where you have agreed for us to get in touch, we will be doing so based on your consent and you can withdraw this at any time.
You apply for a job with us
If we advertise a job posting or you are interested in working as a contractor for us, we may process some of your personal data so as to take steps to enter in to a contract with you.
Typically, we will process your name, contact information and your CV and cover letter. Depending on the route you came in to us, we may also look at your publicly available profiles in advance of an interview, such as a LinkedIn page or a professional Twitter account. We will also contact those you offered as a reference for you.
If you let us know about a disability or health condition (or provide us with any other special category data), we will process this data under our legal obligations in relation to employment and equality laws.
If you are successful in your application and we want to offer you a job, we will process more information than this. To see our employee privacy notice, please contact firstname.lastname@example.org.
You use our website
However, some cookies and tagging/ tracking technologies that we use, such as Google Analytics, do let us know some information which may constitute personal data. An example of this is our Google Analytics Cookies that tell us about which of our pages a certain IP address accessed, when and where it was accessed from.
Consent is required for all cookies except essential cookies and you can adjust your preferences using the preference centre tab displayed on the home page.
You attend one of our training courses
DPAS will process the names, attendance dates, job title, and place of work data of attendees, per its obligations to fulfil the terms of the contract. If our contract is directly with the attendee, we will rely on the legal basis of contract to process this data. If our contract is with the employer, we will rely on the legal basis of legitimate interests to process this data. DPAS will maintain this data for 6 years after the course completion date, per industry best practice and the Limitation Act 1980. This data will be processed on our CRM for this purpose only. DPAS have a contract in place with this CRM provider. This data will also be shared with the trainer on the day of the course, who will have a contract with DPAS. To find out the identity of this trainer in advance of this information being shared, please contact email@example.com
DPAS may process the payment details of the client, through our website and using our accounting provider, Xero Ltd. DPAS will maintain a record of this payment for six years, per its legal obligations under the Limitations Act 1980. Card payment details will not be retained beyond immediate use in the payment gateway. Payment status will be held on our CRM and accessed by limited DPAS employees for this purpose only. DPAS have a contract in place with Xero, whereby they and their sub-processors meet EEA standard adequacy arrangements.
DPAS will process information relating to attendee transport, as per our legitimate interest to organise the logistics of the course. With your explicit consent, we may also need to process information relating to disabilities (in some circumstances) and dietary requirements for the same reason. DPAS will retain this information for up to a maximum of 30 working days post course completion. This data will be processed on our CRM for this purpose only.
DPAS and our trainers will access the names, of attendees, and any answer sheets and pass or fail status per our contractual obligation to award the CPD credits and BCS certificates. DPAS will also collate statistical evidence using this personal data to evaluate the effectiveness of training, to improve upon the courses and to assist DPAS in providing further advice to the Client. DPAS will keep this in an identifiable form for 1 year only, after which, any statistical conclusions will be kept in an anonymised format. This data will be stored on Arlo CRM for this purpose only. DPAS have a contract with this software provider. DPAS will also share the pass/ fail status of attendees with the Continuing Professional Development body, where required to by contract.
DPAS offers accredited training courses and to enable delegates to sit their chosen exams DPAS must pass some personal information to the professional accrediting bodies. This will enable candidates to sit their exam and gain access to their BCS associate membership.
DPAS delivers accredited training courses for the Chartered Institute for IT – BCS. DPAS have signed a Provider Contract with the BCS which allows us to deliver the following BCS Certified training courses:
BCS Foundation Course in Data Protection
BCS Practitioner Course in Data Protection
BCS Practitioner Course in Freedom of Information
DPAS is not a Data Processor for, nor does it process personal data on behalf of the BCS.
Our BCS Accredited Training Provider status does not infringe upon our personal data collection practices. We will only share your personal information with BCS when we have to in order to fulfil our contract with you. We share the delegates name and email address at their request when they inform us that they wish to sit a BCS exam. We only pass across these details once the delegate has confirmed the specific exam date (usually included within the classroom training course) and where applicable have completed their exam prep and mock exam successfully. The BCS then contacts the delegate directly to create a log-in portal on their site. DPAS does not have access to the delegate portal.
We are required to provide the BCS feedback from delegates regarding courses they have attended. Delegates receive a feedback form at the end of their course, which enables us to fulfil our obligation to the BCS, and also allows us to improve the quality of our training services. We are grateful to all delegates that complete these forms, including giving your name to enable your comments to be used.
The BCS share your exam results (marks only) with DPAS as we are the Accredited Training Provider (ATP). This benefits us in a number of ways:
- It enables us to monitor the success of our training
- It helps us to improve the service we offer you
- It allows us to maintain a record of exam results for our delegates
We will not share this information with any third party.
We become business associates/connections
If you are a business connection, for example, we meet you at a networking event, we will only collect the information you choose to provide to us which typically includes your name, company address, company telephone number and company email address. Our legal basis for processing your information is legitimate interests and we will retain it for 12 months following our last meaningful contact.
We contact you for marketing purposes
Where we have publicly found your contact details (e.g. firstname.lastname@example.org), we may send you business marketing information by email where we think you may be interested in our products or services.
Where we have a corporate email address for you which contains identifiable information (e.g Joe.email@example.com) we may send you business marketing information by email, if we think your products or services may be of interest to you. We may also telephone you to discuss our products and services providing your telephone number is not listed on the Corporate Telephone Preference Service list (CTPS).
You have the right to object, and if you do we will respect your wishes and remove you from our mailing list, if this is the case please email firstname.lastname@example.org.
How do we use your personal information now that we have collected it?
We use personal information about you in connection with the following purposes:
Fulfilling your requests:
- Respond to you following a DPO related request, concern or casework activity;
- Provide you with the information, products and services that you have requested from us;
- Complete any transaction you are undertaking with us;
- Carry out our obligations arising from any contracts entered between you and us;
- Allow you to participate in interactive features of our service, when you choose to do so;
- Process a job application or enquiry and;
- Meet a legal or statutory obligation.
- Provide you with information, suggestions and recommendations about other goods and services we offer that are similar to those that you have already purchased or enquired about (unless you have opted out);
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or the website of another DPAS Company or third parties’ websites (the information we use for this purpose is collected using cookies and you can adjust your cookie settings by clicking on cookie settings on our website).
Before getting in touch by telephone, we will always check against the Telephone Preference Service (TPS) and/or the Corporate Telephone Preference Service (CTPS), whichever is appropriate.
We never market to data subjects who have contacted us when acting in our capacity as a DPO.
If you no longer wish to be contacted for marketing purposes, please email: email@example.com. or click on the unsubscribe button at the bottom of the emails we send.
Service Improvements and account management:
- To ensure that content from our site is presented in the most effective manner for you and for your computer;
- To administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To notify you about changes to our service;
- To manage and operate your account with us.
We do not use profiling or automated decision-making tools.
How long do we hold your personal information?
We will hold your data for no longer than we need it for. This will be context dependant on our relationship with you and why we are processing your data. We may have legal (i.e. financial obligation) reasons to keep your data beyond its immediate use, but this will never be for longer than industry standard.
All DPO related casework will be held for a minimum of 6 years before being destroyed.
Where not already stated in this policy, you can view our retention schedule by contacting us directly.
Sharing your personal information
In our capacity as a DPO we may have to discuss your case with your Data Controller. We will try and do this in most cases without disclosing personal details. However, in some cases it will be impossible to do so without disclosing your name or other identifiable information. In that instance we will always advise you before contacting the Data Controller.
We will never use your information for any other purpose if you have contacted us in our capacity as a DPO.
If we have a business relationship with you, we may pass some information to our third-party service providers, agents, subcontractor and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we will always have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond the DPAS Network for them to use for their own direct marketing purposes, unless you have consented to this.
These third parties services providers may include:
- Fresh Desk – Customer ticketing system
- Fresh Sales – Customer management system
- Arlo – Training Management System
- WordPress – Website
- Xero – Invoicing Software
- Knowledge Zone – Elearning Platform
- Mailchimp – Email Marketing
We may share your information with credit reference agencies and other companies for use in credit decisions and for fraud prevention.
We may share your information with third party contractors or organisations working with DPAS to fulfil supplier contracts. We will only share information that is relevant to fulfilling your request. For example, if you are booked onto a DPAS training course, we will share your information with the course trainer.
We operate internationally. As part of the services offered to you by DPAS, the information, which you provide to us may be transferred to countries outside the European Union (“EU”) and the European Economic Area (EEA).
By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.
We take appropriate technical and organisational measures to safeguard your personal information when transferring it outside the EEA as we:
- only allow personal data to be processed in countries which the European Commission have confirmed have adequate protection for personal data (see European Commission: Adequacy of the protection of personal data in non-EU countries) and/or;
- we enter into appropriate contracts which the European Commission have confirmed provide adequate protection for personal data (see European Commission: Model contracts for the transfer of personal data to third countries)
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
Controlling your PERSONAL information for marketing
You have a choice about whether or not you wish to receive marketing information from us.
You have the absolute right to object to us processing your personal information for marketing purposes and to withdraw your consent when that is the basis we rely on.
You can exercise these rights and change your marketing preferences at any time by contacting us by email: firstname.lastname@example.org
Where we have your business contact details (e.g. Information@example-corporation.com) and no personally identifiable information, we may send your business marketing information by email where we think you may be interested in our products or services.
Where we have a corporate email address for you which also contains identifiable information (eg: Joe.Bloggs@example-corporation.com) we may send you business marketing information by email if we think that our products and services may be of interest to you. However, as stated above, you have the right to object and if you do, we will respect your wishes and we will not send you any further marketing material by email.
Your data rights:
The accuracy of your information is important to us and, if the personal data we hold about you is incorrect, you have a right to have it rectified. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold about you is inaccurate or out of date, please email us at: email@example.com
You have the right to ask for access to a copy of the personal information DPAS holds about you. This is known as a Subject Access Request and there is no charge for this, providing the requests are not manifestly unfounded or excessive. We may ask you to provide ID before processing the request. Once in receipt of this, we will process the request without undue delay and within one month. You also have rights in relation to erasure, restriction, data portability and objections. We do not use automated decision-making tools. If you would like to exercise your rights, please contact us at firstname.lastname@example.org or on telephone number 01392 914019.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
Our Data Protection Officer is Nigel Gooding and you can contact him at: email@example.com.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). Information about how to complain to the ICO can be found here: https://ico.org.uk/make-a-complaint/
Keeping your personal information safe
We will never keep paper copies of any of your personal data.
We have a duty under law to keep all DPO casework confidential. Only our trained DPO staff will review the information you have sent and ensure it is kept within the secure email system and secure ticketing software.
All DPO casework is password protected and securely held.
We use Google Cloud platform to store some personal information as it provides some of the best cyber security in the business. To read the detailed specification of how they keep your data safe, please click on the link below.
We use Arlo, Fresh Sales and Fresh Desk to manage potential customers and current customers information. This system has servers in the EEA and your data will be hosted there. For more information on this, please contact firstname.lastname@example.org
Non-sensitive details and non-DPO emails (your email address etc.) are transmitted normally over the Internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Keeping children safe
We are concerned to protect the privacy of children aged under 18. If you are aged under 18‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible, unless we have a legal obligation to process it, for example as part of our role as DPO.
Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at: DPO@dataprivacyadvisory.com.
Links to other websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
This policy was updated on the 21st September 2020.