All staff have been made aware in our organisation that the law is changing with regard to an individual’s rights to have their personal data protected. These changes are set out in the General Data Protection Regulations which come into effect on the 25th May 2018. The GDPR will be similar to the existing UK Data Protection Act 1998 (DPA) but brought up to date and with many more legal requirements. The UK agency that will be responsible for enforcing the GDPR is the Information Commission’s Office (ICO). Once the GDPR comes into effect there are significant financial penalties that can be enforced for a data breach or a failure to follow the stipulations under GDPR or a failure to obtain formal consent.
We may collect, store and use the following kinds of personal information:
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. We may use both “session” cookies and “persistent” cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website.
We will use the persistent cookies to: enable our website to recognise you when you visit. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
Asking for consent
We consider that consent is the most appropriate lawful basis for processing personal data.
The request for consent is prominent and separate from our terms and conditions.
We ask people to positively opt in.
We don’t use pre-ticked boxes or any other type of default consent.
We use clear, plain language that is easy to understand.
We specify why we want the data and what we’re going to do with it.
We give individual detailed options to consent separately to different purposes and types of processing.
We name our organisation and any third party controllers who will be relying on the consent.
We tell individuals they can withdraw their consent.
We ensure that individuals can refuse to consent without detriment.
We avoid making consent a precondition of a service.
A record is kept of when and how we gained consent from an individual.
We regularly review consents to check that the relationship, the processing and the purposes have not changed.
There are processes in place to refresh consent at appropriate intervals, including any parental consents.
Individuals may withdraw their consent at any time, and we publicise how to do so.
Withdrawals of consent are acted on as soon as possible.
We will not penalise individuals who wish to withdraw consent.
Legitimate Business Interests
We consider that legitimate interests is also another appropriate basis for processing and storing of for instance photographic images.
We understand our responsibility to protect the individual’s interests.
We have conducted a legitimate interest’s assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
We have identified the relevant legitimate interests.
We have checked that the processing is necessary and there is a no less intrusive way to achieve the same result.
We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests.
We only use individuals’ data in ways they would reasonably expect unless we have a very good reason.
We are not using people’s data in ways they would find intrusive or which could cause them harm unless we have a very good reason.
We have considered safeguards to reduce the impact where possible.
We have considered whether we can offer an opt-out.
If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA.
We keep our LIA under review and repeat it if circumstances change.
We include information about our legitimate interests in our privacy notice.
Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password- and firewall- protected) servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology. All information is handled in accordance with the data protection act 1998. Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
Any breach which leads to accidental, unlawful destruction or the loss or alteration of personal data will be notified to the ICO within 72 hours and to all affected individuals without undue delay.
You have the absolute right to object to your data being processed and profiled for direct marketing purposes. You have the right to have your information withdrawn at any time.
Your information will be provided to you within one month and no fee will be levied. You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to:
Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
Please let us know if the personal information which we hold about you needs to be corrected or updated.
The data controller responsible in respect of the information collected at Finanta Ltd