Last updated on: 31.01.2020
GAP Communications respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, about your privacy rights and how the law protects you.
1.1 This Notice
This privacy notice gives you information on how GAP Communications collects and processes your personal data through your use of our website, including any data you may provide when you make an enquiry about or commission a Questant Process or sign up to hear more from us. We also collect and process your personal data through the contact we have with you, by telephone, email and post.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 Data Controller
GAP Communications is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Jo Lloyd, owner of GAP Communications is the Data Protection Officer. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please do contact us using the details set out below.
1.3 Contact Details
Our full details are: GAP Communications
Data Protection Officer: Jo Lloyd
Email address: firstname.lastname@example.org
Postal address: 55 Loudoun Road, Newmilns, KA16 9HJ
At any time, you have a legal right to make a complaint to the Information Commissioner’s Office (ICO), (www.ico.org.uk). We would, however, appreciate the opportunity to address and deal with your concerns before you approach the ICO, so please contact us in the first instance.
1.4 Changes by Us and by You
This version was last updated on the date stated.
It is important that the personal data we hold about you is accurate and current. If, during your relationship with GAP Communications, your personal data changes please keep us informed.
1.5 Third-Party Links
The Questant website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. GAP Communications does not control these third-party websites and is not responsible for their privacy statements. You should read the privacy notice of every website you visit.
1.6 Data Collected
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use and store different kinds of personal data about you which we have grouped together as follows:
- Identity Data like your name and your title (Mr, Ms, Miss etc.)
- Contact Data includes your address, email address and telephone number, including mobile numbers.
- Transaction Data includes details about payments and other details of services you have commissioned from us.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
How is my personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- ask for a quotation;
- correspond with team members;
- request marketing to be sent to you;
- enter a competition, promotion or survey promoted by us;
- give feedback
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your IT/computer equipment, browsing actions and patterns and your Usage Data in respect of your use of our website. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Identity, Contact, Financial and Transaction Data from providers of technical and payment services based inside the EU, such as Sage Pay.
- Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.
How we use your personal data.
- Where we need it to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.We only use your personal data when the law allows us to.
2.0 Purposes for which we will use your personal data
We use your personal data to:
- provide you with the information, products and services that you request from us
- manage and administer our business
- review and improve our services
- provide you with marketing information in accordance with your marketing preferences
- personal data that we receive from third parties (if any) is combined with the personal data that you provide to us and used for the purposes described above.
3.0 Marketing & Your Personal Data
We will add your details to our marketing database if you you make an enquiry (on-line or offline) about our services or you buy our services
We may send you marketing communications by email, telephone, text message or post.You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), or you may ask us not to send you any marketing communications at all. We may ask you to indicate your marketing preferences when you first make an enquiry. You can check and update your current marketing preferences at any time by contacting us.
4.0 Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If this requires your consent, you are not required to give your consent just because we ask for it. If you do give your consent, you can change your mind and withdraw it at a later date by contacting us. Please note: we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of Your Personal Data: We may have to share your personal data if required to do so by statutory bodies (like the Police and HMRC).
International Transfers: No international transfers of personal data are made by GAP Communications
Data Security: We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention: We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and any legal and contractual requirements we are subject to for example: by law we have to keep basic information about our clients (including Contact, Identity and Transaction Data) for six years after they cease being clients for tax purposes.
We may also be subject to contractual requirements from external third parties that specify how long we need to store your personal data for. For example: a local authority who funded a Questant Process for a community group may require us to keep data for up to 10 years.
In some circumstances, you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
5.0 Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the Data Controller.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means conducting and managing our business in our interests, or the interests of a third party. In addition to providing services to you, our interests also include, for example, our internal administrative purposes, marketing and ensuring network and information security. Whether a particular legitimate interest may exist can also depend on the relationship we have with you (for example, where you are a customer of ours).
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests or the interests of a third party.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
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.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
GAP Communications 2020