1.0 About this Policy
This privace policy appliues to all Course Finder 365 users and visitors. We reserve the right to edit and change this policy as needed.
1.1 Document Control
The document is to be reviewed annually and updated.
1.2 Policy Purpose
The purpose of the Course Finder 365 Policy and Statement is to ensure that all personnel whom we deal with either as prospective customers, customers, suppliers or employees fully understand the company’s commitment to meet or exceed all the GDPR legislation that is relevant to the company and the services it provides.
If you have any questions about this privacy notice or how we use your personal data, please contact our compliance team:
Course Finder 365
28 Church Lane
By Email: firstname.lastname@example.org
All published on website.
2.0 The Policy
The EU General Data Protection Regulations (GDPR) require all companies to treat personal information collected or handled securely and maintain accurate records as to how this information is stored and used. Course Finder 365 recognises that your privacy is important. This document details the information regarding personal data that Course Finder 365 collects, stores and uses.
Course Finder 365 will comply in full with the principals of the GDPR that requires that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals;
- Collected for specified, explicit and legitimate purposes and not further processed
- in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date; every reasonable step must 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;
- 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;
- 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.
2.2 How we collect personal information
Course Finder 365 collect personal information via the following means:
- Personal Meetings.
- Telephone Calls
- Online web and printed Forms
- Research or referrals.
- Transferred by a Third Party in relation to services offered (eg. Mail Fulfilment).
- Employee details during Induction and employment.
As of the 1st July 2017 we are in the process of re-obtaining positive permission for all personal information held and stored in order to comply with the GDPR.
2.3 The type of personal information we collect and store
The Type of Information Collected and Stored by Course Finder 365:
- Work Title
- E-mail address
- Employers address
- Telephone Number
- Bank Account Details restricted to Account Name, sort Code and Account Number
- Additional Personal Information such as hobbies, interests, family details etc – used to establish rapport.
The Type of Personal Information transferred to Course Finder 365:
The information that is required by Course Finder 365 is often a subset of a much larger data set that may contain a much wider set of personal information than that required by Course Finder 365 to fulfil their services. This information may include:
- Work Title
- Home address
- Family Details
- Income Details
- E-mail address
- Telephone Number
- Mobile Number
2.4 How we use personal information
Course Finder 365 may use your personal information to:
- Administer and pay our employees.
- Contact our customers relating to past present and future sales.
- Collect Payments and send Invoices and Statements.
- Administer and Personalise our web sites or e-mails.
- Send marketing information.
- Supply products and services.
Course Finder 365 employs a “need to know” policy of sharing information between its employees, agents or subcontractors and will only disclose sufficient information to allow our employees, agents or subcontractors to complete their objectives and as such these parties will be obligated to use that personal information in accordance with the terms of this privacy statement.
In addition to the uses described above Course Finder 365 may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
Direct Marketing Communications
We strive to make sure we provide only interesting and relevant marketing communications. And you can opt-out at any time.
If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.
To help make our emails more interesting and relevant, we often receive a confirmation when you open an email from Course Finder 365 if your computer supports such capabilities.
You have a right to opt-out of our direct marketing communications at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication.
Client Website Data
All Course Finder 365 client data for hosted websites, is held by our hosting company suppliers secure servers. Whilst the data held within clients websites is owned, retained and is the responsibility of the client, Course Finder 365 can control and have access to this data. Course Finder 365 will never use this data for any other purpose than in the interest of the client owning the data. If a client wishes to know which hosting company holds the data, where the data is stored and who has access to this data, please email email@example.com or call 020 3973 0080 and our compliance team will give you the details required.
If a client wishes to delete data from their website it is their responsibility as the website owner. If a client wishes to task Course Finder 365 with deleting this data, an hourly charge of £60 will be applied to book this work in and actioned.
This is how we will protect your data
In order to protect the personal data collected from you by Course Finder 365 against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors and other support staff are obligated to observe confidentiality and data privacy.
Any access to your data that is stored at our company only takes place through an encrypted connection. By using the most up-to-date firewall systems, we provide the best possible protection for your data. Our website, as well as our internal Customer Management System (CMS) is encrypted using a SSL/TSL (Secure Sockets Layer/ Transport Layer Security) connection. SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers.
Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.
All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation. You must not use any false identity in email or other network communications and you must not attempt or participate in the unauthorised entry or viewing of another user’s account or into another system.
2.6 What we will do in the event of data being compromised
If at any time we become aware that your data has been compromised, or that a breach of our systems and controls has occurred, which has an impact on the security of your data, we will notify the Information Commissioner’s Office, and you, without undue delay.
2.7 Our lawful basis for processing this data
If the personal information has been collected by Course Finder 365 we will ensure we have your permission to use the data necessary for the fulfillment of services provided or in order to take steps to procuring further orders.
If the personal information is transferred to Course Finder 365 for the purposes of fulfilling a service we will obtain a statement from the transferee that they have the consent of all personnel to which the information refers before entering into a contract.
2.8 Data Retention
All data transferred to us by third parties will be stored in a restricted area of our secure server.
It will be held there until either the data is no longer required or the transferee has requested us to destroy the data. Data transferred to us will be disposed of using an electronic shredder. Data that has not been used will be destroyed by secure means after a period no greater than 12 months.
All data collected on employees will be held for at least 5 years after employment ceases for archiving purposes unless requested to do otherwise.
All data collected on customers or potential customers will be held whilst ever that data is considered useful or unless requested to do otherwise. The Data will be reviewed at least annually.
2.9 Your rights
All personnel that Course Finder 365 hold personal information on have the following rights:
- The right to be informed of the data being held.
- The rights of access to the information being held.
- The rights to rectification of any errors in the information being held.
- The rights to have the information destroyed.
- The rights to restrict the use of the information.
Subject Access Request
You can request a copy of the data we hold on you at any time and will provide it within 1 month of receiving your request in writing, if not sooner.
You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 Inc. VAT when a request is manifestly unfounded, excessive or repetitive.
We will provide this information in a structured, commonly used and machine-readable forms such as a CSV file or PDF file where possible. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Where possible, we will provide this information via remote access to a secure self-service system, such as our Customer Account area, which would provide you with direct access to your information.
If you would like to submit a Subject Access Request, please contact our compliance team in writing to:
Course Finder 365
28 Church Lane
We will respond to your request without delay and at the latest, within 1 month of receipt of your request.
2.10 Updating this statement
You should check this page occasionally to ensure you are familiar with any changes.
2.11 Contacting Course Finder 365
By email to firstname.lastname@example.org
By post to: Privacy Manager, Course Finder 365, 28 Church Lane, Marple, Stockport, SK6 6DE
2.12 Making a complaint
If you have a concern about Course Finder 365’s information rights practices, you should report it to the ICO by accessing by either e-mailing email@example.com or accessing their web site www.ico.org.uk
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