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Privacy Notice

 

1. About this Notice  

  1. This Privacy Notice explains how Digital Skills Consulting (DSC) use any personal information that it may collect about you. It is committed to ensuring that your privacy is protected in accordance with the law, and all Personal Data shall be held and used in accordance with the UK laws relating to data protection and privacy.
  2. This notice, together with our Terms of Use, sets out the basis on which any Personal Data that DSC collects from you, or that you provide to us, will be processed. We do update this policy from time to time, so please do review this notice regularly.
  3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice that DSC 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 Personal Data. This privacy notice supplements those other notices and is not intended to override them.

2. Personal Data collected by DSC  

  1. Personal Data means any information about an individual from which that person can be identified. DSC may collect, use, store and transfer different kinds of Personal Data about you which has been grouped together as follows:
    • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender
    • Contact Data includes address (home, postal or other physical address), email address and telephone numbers
    • Usage Data includes information about how you use our services
  2. Personal Data does not include data where your identity has been removed or which is not associated with, or linked to, your Personal Data (anonymous data).
  3. DSC may also collect, use and share Aggregated Data such as statistical or demographic data for research purposes. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity.
  4. Where DSC needs to collect Personal Data by law, or under the terms of a contract, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have requested. In that event, we will notify at the time.

3. How DSC collects Personal Data  

  1. DSC will only collect data from and about you through direct interactions. You may provide your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, via the website or otherwise, or when you enter into a contract with us for the provision of services.
  2. This includes the following interactions:
    • When you agree to become a Client, Partner or Sponsor, data you provide to DSC is added to the database
    • When you make any enquiry about DSC and give permission to be added to the database, your data is added
  3. Personal Data does not include data where your identity has been removed, or which is not associated with or linked to your Personal Data (anonymous data)
  4. DSC will also ask you from time to time to update your contact details, communication preferences, location, and interests.

4. How DSC uses Personal Data  

  1. DSC will only use your Personal Data when the law allows us to. We may collect and process the Personal Data about you for the following purposes:
    • Requesting DSC services – we can/will use your Identity, Contact and Transaction Data in order to register you and to process and deliver services, including the management of payments. This is necessary for the purpose of contracting with you.
    • Contacting DSC – when you contact us with an enquiry, or to request information (including leaflets and other hard copy materials), we will use your Identity and Contact Data to respond to you.
    • Advertising, Marketing and Public Relations:
      • DSC may use the Identity, Contact, and/or Usage Data of our clients, partners or sponsors to form a view on what they may want or need, or what may be of interest to them.
      • In doing so we will only send information that is deemed relevant to the use of our services. This is necessary for DSC’s legitimate interests in growing and developing the services offered.
      • Clients, partners and sponsors will receive marketing communications from DSC if they have requested information or purchased services and, in each case, have not opted-out of receiving that marketing.
      • DSC will not share Personal Data with any third-party for marketing purposes. You can ask us to stop sending marketing communications at any time by contacting DSC.
      • DSC will use your Identity and Contact Data for the purposes of communicating information about relevant company information, information about support services, sending newsletters, promoting benefits and/or services and notification of events, as well as the establishment of networking groups, fundraising requests, volunteering opportunities and/or work placements.
    • Surveys – If you choose to complete a survey that DSC uses for research purposes, we will retain the information that you provide in response to that survey. This is necessary for our legitimate interest in understanding our clients, partners & sponsors, and developing and informing DSC’s marketing strategy.
    • Information to clients, partners & sponsors about our progress, specifically in relation to performance, funding, sponsorship and/or other activities.
    • Administration – DSC may use your Identity and Contact Data for the purpose of protecting our business and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
      • This is necessary for our legitimate interest in running our business, the provision of administration, IT services, networks and cyber security, to prevent fraud and for compliance with our legal obligations.
    • Website Analytics – as you navigate our website, Usage Data may be collected automatically. This is done to find out things such as the number of visitors to the various parts of the website, to help to improve the content of our website and to customise the content or layout of the website for you, in accordance with DSC’s legitimate interests.
      • This is necessary for our legitimate interest in defining types of clients, partners & sponsors, to keep our website updated and relevant, to develop the company and to inform our marketing strategy.
    • Fault Reporting – if you contact us to report a fault with the website, we will use the Identity and Contact Data provided for the purposes of rectifying that fault in accordance with DSC’s legitimate interests.
    • Recruitment – Personal Data provided for an employment opportunity will be processed so as to allow us to process and evaluate the merits of that application in accordance with our legitimate interests.
  2. DSC may also use Personal Data which you provide, where the law allows us to do so, as follows:
    • To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us, or as a result of such contract or agreement.
    • Where we need to perform the terms of the contract DSC is about to enter into or has entered into with you.
    • Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
    • Where it is necessary for DSC’s legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests.
  3. DSC does not generally rely on consent as the legal basis for processing your Personal Data, other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting DSC.
  4. Where we process Personal Data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of DSC in conducting and managing our business to enable us to give you the best service and the best and most secure experience.
  5. DSC will make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for 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 DSC.
  6. DSC will only use your Personal Data for the purposes for which it is collected, 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact DSC.
    • If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
  7. Please note that DSC may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  8. DSC complies with the seven principles of GDPR, set out below, taken from the ICO website.
    • Personal Data shall be :
      • processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’)
      • 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 (‘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 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 (‘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; 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 (‘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’)
      • held with appropriate measures and records in place to be able to demonstrate compliance (‘accountability’)

5. Disclosure of Personal Data to Third Parties  

  1. Your Personal Data will only be disclosed to those DSC employees or workers that have a need for such access for the purpose for which it was collected.
  2. Your Personal Data will not be disclosed to any other individuals or other entities except in the following circumstances:
    • On occasion, DSC needs to hire other companies to help us to serve you better and in some of these cases we may need to share Personal Data that is necessary to perform tasks, such as market research or issuing marketing materials. These third parties may for example be printers, couriers, researchers engaged to carry out research.
    • Where it is necessary for the performance of our contract with you, including where you have asked us to do so, or where DSC needs to take steps to enforce any contract which may be entered into between ourselves and you.
    • Where DSC is under a legal duty to do so in order to comply with any legal obligation.
    • In order to protect the rights, property or safety of DSC, our employees and others – this includes exchanging information with other companies and organisations for the purposes of cyber-crime, fraud prevention and credit risk reduction.
    • If DSC, or substantially all our assets are acquired by a third party, in which case Personal Data that we hold about our customers will be one of the transferred assets.
  3. DSC requires all third parties that process Personal Data on our behalf to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions.

6. Security  

  1. DSC is committed to ensuring that your Personal Data is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect.
  2. In addition, the access to, and use of, the Personal Data that we collect is restricted to DSC employees who need the Personal Data to perform a specific job role or activity. Where Personal Data is shared with third parties, responsible measures are used to protect your Personal Data.
  3. DSC has 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.
  4. The transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the DSC website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
  5. DSC urges you to take every precaution to protect your Personal Data when you are on the internet.

7. International Transfers  

  1. DSC will not transfer Personal Data outside of the United Kingdom without the express prior consent of our clients, partners and/or sponsors.

8. Data Retention  

  1. DSC will only retain your Personal Data for as long as necessary to fulfil the purposes we have collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
  2. To determine the appropriate retention period for Personal Data, we have considered 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 have processed your Personal Data and whether we can achieve those purposes through other means, as well as the applicable legal requirements.
  3. In some circumstances DSC 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.

9. Your Rights  

You have the right to:

  1. 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 that DSC holds about you and to check that we are lawfully processing it.
  2. 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.
  3. 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 to continue to process it.
  4. Ask DSC to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your Personal Data unlawfully or where we are required to erase your Personal Data to comply with local law.
    • Please 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.
  5. Object to processing of your Personal Data where DSC is 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.
  6. Object where DSC is processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.
  7. Request restriction of processing of your Personal Data. This enables you to ask DSC to suspend the processing of your Personal Data in the following scenarios:
    • if you want us to establish the data’s accuracy
    • where our use of the data is unlawful, but you do not want it to be erased
    • where you need us to hold the data even if it is no longer required as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data, but we need to verify whether it has overriding legitimate grounds to use it
  8. Request the transfer of your Personal Data to you, or to a third party. DSC will provide to you, or a third party you have chosen, your Personal Data – in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we have used the information to perform a contract with you.
  9. Withdraw consent at any time where DSC is 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.
  10. You can ask DSC to stop sending you marketing messages at any time by following the “Unsubscribe” links on any marketing message sent to you or by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a purchase, product/service experience or other transactions.

10. Other Websites and Links  

  1. The DSC website may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and we are not responsible for their Privacy Statements or for the content, accuracy or opinions express in such websites.
  2. DSC does not investigate, monitor or check third-party websites for accuracy or completeness and the inclusion of any linked website on or through the DSC website does not imply our approval or endorsement of the linked website.
  3. If you decide to leave this website and access these third-party websites, plug-ins and/or applications you do so at your own risk. DSC encourages you to read the privacy notice of every website you visit.

11. Changes to this Privacy Notice  

  1. This version was last updated in November 2021.
  2. It is important that the Personal Data which DSC holds about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with DSC.

12. Contact Details  

  1. Questions, comments or requests about your Personal Data can be sent to:
    Michael Klonowski
    26 Queen Victoria Street, Reading, RG1 1TG, United Kingdom
    Michael.Klonowski@digitalskills.consulting

13. Complaints  

  1. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://www.ico.org.uk), however DSC would appreciate the chance to deal with your concerns before you approach the ICO.