Do we need your consent?
We do not need your consent if the relevant processing is based on one of the permitted grounds (some of which are set out above), and for Special Categories of Data where permitted exceptions apply. If we wish to rely on your consent for processing your personal data, we will provide you with full details of the proposed processing activities and the reason(s) we are seeking your consent, so that you can carefully consider whether you wish to consent and you may withdraw your consent at any time.
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 have an explanation as to 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.
Please note that 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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above:
- Internal Third Parties as set out below.
- External Third Parties as set out below.
We will share your personal data with third parties only where we are permitted to do so in accordance with applicable legislation, primarily where we are required to do so by law, where it is necessary to administer a contractual relationship with you or where we have a legitimate interest in doing so.
We will require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Internal Third Parties
Other associated companies acting as joint controllers or processors.
External Third Parties
- Service providers acting as processors who provide IT, system administration services and office administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
6. International transfers
We may share your personal data with companies associated with HCP. This may involve transferring your personal data outside the UK.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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 employees, agents, contractors and other third parties 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 suspected breach where we are legally required or it is appropriate to do so.
8. Data retention: How long will you use my personal data for?
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, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
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 the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available by contacting us at email@example.com. In some circumstances you can ask us to delete your personal data: see below for further information.
9. Your legal rights
Your rights in connection with your personal data
Under certain circumstances, by law 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 lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- 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 exercised your right to object to processing (see below);
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and the circumstances of your particular situation mean you wish to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes (including profiling);
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
- request the transfer of your provided personal data to another party.
Please note, however, that certain personal data may be exempt from such access, correction and deletion requests pursuant to applicable data protection laws or other laws and regulations.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If we have another legitimate basis for processing information in law, we may still process the same data and we will not require your consent to do so.
No fee usually required
You will not ordinarily be required to pay a fee to access your personal data (or to exercise any of the other rights), but we may charge a reasonable fee for any additional copies of the materials we provide. Where your request is manifestly unfounded or excessive, we may also charge a reasonable fee or alternatively, we may refuse to comply with the request.
What we may need from you
We may request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it, and in order to help us meet our obligations.
Time limit to respond
We will 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.
If you want to make a request in respect of your rights relating to your personal data, please contact the DPR in writing by emailing us at firstname.lastname@example.org.
If your request or concern is not satisfactorily resolved by us, you can contact the Information Commissioner's Office (https://ico.org.uk/global/contact-us/).
Legitimate Interest means the interest of our business in conducting and managing our business. 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. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your personal 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.
Special Categories of Personal Data means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.