FreeBird Associates is committed to safeguarding your privacy. Contact us at firstname.lastname@example.org if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed. Often this means delegates booking onto courses s and other contacts of the organisation.
We/us (either capitalized or not) – FreeBIrd Associates
Data Protection Principles
We promise to follow the following data protection principles:
· Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
· Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
· Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
· Processing is limited with a time period. We will not store your personal data for longer than needed.
· We will do our best to ensure the accuracy of data.
· We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
When you supply your personal details to FreeBIrd Associates they are stored and processed for 3 reasons:
1. To provide you with the service you have purchased from us, sending you confirmation and reminders of your bookings.
2. On receiving a request from yourselves, and therefore we have your consent, share with regulatory / commissioning bodies what training you or your organisation have received from us.
3. If contacted by CQC, Safeguarding Adult’s Board, to confirm if you have ( or your organisation has) attended Safeguarding Adult’s and related Training, with dates but no comment on ability / knowledge.
4. Again, provided we have your consent, we may occasionally send you general in the form of what updates we have and any new courses we are providing.
5. Publicly available information. We might gather information about you that is publicly available. Such as Organisation purpose.
How we use your Personal Data
We use your Personal Data in order to:
· provide our service to you. This includes for example providing and monitoring training places and notifying you of changes to any courses.
· enhance your customer experience;
· fulfil our obligation under law as outlined above;
· We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of fulfilling our obligations, we Process your Personal Data for the following purposes:
· to identify you;
· to provide you with our service;
· to communicate either for bookings, invoicing or other matters;
We will hold your information for a maximum of 3 years and you can ask us to delete your records if you wish prior to this date
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
· to administer and analyse our customer base (behaviour and history) in order to improve the quality, variety, and availability of services offered/provided;
· to conduct questionnaires concerning customer satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
· to send you newsletters and articles regarding updates to law, policy.
· for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
· the link between purposes, context and nature of Personal Data is suitable for further Processing;
· the further Processing would not harm your interests and
· there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers.. We share your data with:
Our processing partners:
· Eventbrite, a specialist booking system and who process card payments
· Mailchimp , who administer our mailing system
Connected third parties:
·Google, Facebook and similar social media companies who also process data.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Your records are stored:
· On paper, in locked filing cabinets and the offices are always locked and alarmed out of working hours.
· Electronically (in the cloud), using Eventbrite, a specialist booking system service. This provider has given us their assurances that they are fully compliant with The General Data Protection Regulations. Access to this data is password protected, and the passwords are changed regularly.
· On our office computers. These are password protected, backed up regularly, and the offices are locked and alarmed out of working hours.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
We do not intend to collect or knowingly collect information from children, as we provide learning opportunities for Adults.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
· Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
· Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in booking forms so you don’t have to re-enter this information next time when booking.
· Analytics cookies – these cookies are used to track the use and performance of our website and services
· Advertising cookies – if used (we currently do not do so), these cookies deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Data Protection Officer ( not required)
Phone: +44 1625 545 745
Last modification was made May 31st, 2018.