Quality Futures CIC

 

Privacy Policy (last updated Oct 15 2021)

 

 We take your privacy very seriously.  Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data.  It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated in accordance with the UK Data Protection Act 2018 (DPA 2018) including its General Data Protection Regulation (GDPR) provisions.   We are responsible as 'controller' of that personal data for the purposes of DPA 2018. Our use of your personal   data is subject to your instructions, DPA 2018 including the GDPR provisions, other relevant UK legislation and our duty of confidentiality.

Key terms

 

We start by explaining some key terms use in this policy:

We, us, our

 

Our data protection officer

Personal data

 

 

 

Special category personal data

Quality Futures C.I.C.

 

Michael Jellicoe (E: mike@qualityfutures.com T: 07725 277198

Any information relating to an identified or identifiable individual

Personal  data  revealing  racial  or  ethnic origin, political opinions, religious beliefs, philosophical         beliefs    or    trade    union membership

 

Genetic and biometric data

 

Data concerning health, sex life or sexual orientation

Personal data we collect about you

 

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collect

 

Your name, address and telephone number.

 

Electronic  contact  details,  eg  your  email   

and mobile phone number      

 

Information relating to the matter in which

we are  contracting with you.        

Personal data we may collect depending on the work we do for you

 

Information to enable us to check and verify your identity, eg your date of birth or  passport details.

 

Your bank and/or building society details.

 

Details of your professional  online presence eg Linkedln profile.

Data regarding your opinions on matters addressed in our training courses.

 

Your employment and professional status    

 

Information about your use of our IT, communication  and  other  systems,   and other monitoring information, eg if you complete online templates we send to you or you contact us via our website

This personal data is required to enable us  to provide our services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing  services to you.

How your personal data is collected

 

We collect most of this information from you.   However, we may also collect information from other sources:

 

  • From publicly accessible sources,  eg Companies House

  • From a third party with your consent,  eg:

    • Your  bank or building  society;

    • Consultants  and other professionals  we may engage  in relation to your  matter;

    • Your employer;

    • Your doctors,  medical  and occupational health professions;

  • Via  our  website   -   eg:  through   contact   forms   and  the  use  of  cookies   (for  more information,   see  our  Cookies  Policy)

  • Via  our  information technology  (IT)  systems,  eg;  case  management, document management and time recording systems,   meeting recording systems, electronic calendars, telecommunications systems and email.

  

How and why we use your personal data

 

Under data protection law, we can only use your personal data without your specific consent if we have a proper reason for doing so. We rely on three separate reasons to lawfully use your data, which are:

 

  • To comply with our legal and regulatory obligations;

  • For the performance of our contract with you or to take steps at your request before entering into a contract, or

  • For our legitimate interests.

A  legitimate  interest  is when we  have  a  business  or  commercial reason to  use  your information, so long as this is not overridden by your own rights and interests.

 

If we can not rely on one of the above reasons to use your data, for instance if we are to use your special category personal data, we will request your explicit consent to do so.

The table below explains  what we use (process)  your personal  data for and our reasons  for doing so:

What we use your personal data for

 

To provide training and coaching services.

To provide advice regarding the matters on which we contract with you.

Conducting checks to identify our clients and their identity.

Ensuring business policies are adhered to eg  policies covering security and internet. 

 

Operational reasons such as improving  efficiency and quality control.

Ensuring the confidentiality of commercially  sensitive information.

  

Preventing unauthorized access and modifications to systems.

Updating client records.

     

Statutory returns. 

                                       

Ensuring safe working practices and assessments.

Marketing our services to you.  

 

External audits and quality checks

Our reasons

 

To enable the performance of our contract to provide training or advice to you or to take steps at your request before entering into a contract.

 

 

 

To  comply with any legal and regulatory verify obligations.

For our legitimate interests, ie to make sure we are following our own internal procedures.

                                                                  

For our legitimate interests, ie to be as efficient as we can so we can deliver a quality service to you.

 

For our legitimate interests, ie to protect our intellectual property and other commercially valuable information.

For our legitimate interests, ie to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

For the performance of our contract with you or to take steps at your request before entering into a contract.

To comply with our legal and regulatory obligations.

To  comply   with   our   legal   and   regulatory obligations.

To  comply   with   our   legal   and   regulatory obligations.

For our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.

 

For our legitimate interests, ie to promote our business to existing, former and prospective clients.

For our legitimate interests, ie so we can demonstrate  we  operate  at  the  highest standards.

To comply with our legal and regulatory obligations.

The above table does not apply to special category personal data, which we will only process with your explicit oral or written consent.

 

Where your personal data is held

 

Information may be held at our offices and those of our third party service providers as described above (see 'Who we share your personal  data with)'

 

Some of these third parties may be based outside the United Kingdom.  For more information, including on how we safeguard your personal data when this occurs, see below: 'Transferring your personal data out of the United Kingdom'.

 

Promotional communications

 

We may use your personal data to update you (by email, telephone or post) about matters that might be of interest to you and/or information about our existing and new services.

 

We have a legitimate interest in processing your personal data for promotional purposes (see above 'How and why we use your personal data').  This means we do not usually need your consent to send you promotional communications.  However, where consent is needed, we will ask for this consent separately and clearly.

 

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

 

  • Using the 'unsubscribe' link in promotional emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further  services in the future,  or if there are changes in the law, regulation, or the structure  of our business.

 

Who we share your personal data with

 

We would expect to share personal data with:

 

  • Professional colleagues who we work with on your behalf, eg coaches used to deliver our training, specialist advisers such as lawyers and accountants;

  • Our banks and our insurance brokers;

  • External auditors, eg in relation  to the preparation of our accounts;

  • External service suppliers that we use to make our business more efficient, eg document destruction, document storage and Information Technology providers.

 

We only allow our service providers to handle your personal data if we are satisfied they take appropriate   measures to protect your personal data.  We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We  may also need to share some personal data with other parties, such as potential buyers of our business or during a re-structuring.   Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

How long your personal data will be kept

 

We will keep your personal data after we have finished advising or acting for you.  We will do so for one of these reasons:

 

  • To respond to any questions, complaints or claims made by you or on your behalf;

  • To show that we treated  you fairly;

  • To keep records required by law.

 

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

 

When it is no longer necessary to retain your personal data, we will delete  it.

Transferring your personal data out of the United Kingdom

 

To deliver services to you, it is sometimes necessary for us to share your personal data outside the United Kingdom, eg:

 

  • With your and our service providers located outside the UK. Specifically our website and learning platform providers are both  located outside the UK but each confirms they comply with UK GDPR;

  • If you are based outside the United Kingdom;  

  • Where there is an international dimension to the matter on which we are advising you.

When it is necessary for us to share your personal data outside the United Kingdom, we will take steps to ensure your data is protected to an equivalent standard as within the United Kingdom.

 

Keeping your personal data secure

 

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

 

We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud,  identity theft, viruses and many other online problems, please visit www.getsafeonline.org   Get Safe Online is supported by HM Government and leading businesses.

 

Your Access rights

 

You have the following rights, which you can exercise free of charge:

Access

 

Rectification

To be forgotten

Restriction of processing

Data portability

To object

The right to be provided with a copy of your personal data.

 

The right to require us to correct any mistakes in your personal data.

The right to require us to delete your personal data - in certain situations.

The right to require us to restrict processing of your personal data -  in certain circumstances, eg if you contest the accuracy of the data.

The  right  to  receive  the  personal  data  you  have provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party -  in certain situations.

The right to object:

  • At any time to your personal data being processed for direct marketing (including profiling).

  • In certain other situations to our continued processing of your personal data.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under DPA 2018.

 

If you would like to exercise any of those rights, please:

 

  • Email, call or write to our Data Protection Officer-  see below: 'How to contact us', and

  • Let us have enough information to identify you (eg your full name, address and client or matter reference number), and

  • Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

  • Let us know what right you want to exercise and the information to which your request relates.

 

How to complain

 

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

 

The DPA 2018 also gives you the right to lodge a complaint with a supervisory authority.  The supervisory authority in the UK is the Information Commissioner who may be contacted at htms://ico.org.uk/concerns or telephoned at: 0303 123 1113.

 

Changes to the privacy policy

 

This privacy policy was last amended on 15 October 2021.

 

We may change this privacy policy from time to time. Any amendments to this version will be posted on our website. Material changes will be informed to you by post or email.

 

How to contact us

 

Please  contact  our  Data  Protection   Officer   by  post,  email  or  telephone   if you  have  any questions  about this privacy  policy or the information  we hold about  you.

 

Our Data Protection  Officer's  contact  details  are shown  below:

 

Mr Michael Jellicoe

Quality Futures CIC

9, Lansdowne Circus, Leamington Spa, Warwickshire CV32 4SW

mike@qualityfutures.co.uk

07725 277198