At Freevacy your privacy is of the utmost importance. We want you to feel informed over the data we collect about you and in control with how we use it.
About this privacy notice
What is Personal Information?
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify an individual. For example, this could be your name and contact details.
Sensitive Personal Data
Sensitive personal data, (known as Special Category Data) needs greater protection. It refers to information you would not want widely known as it is very personal to you. This includes anything that can reveal your:
- sexuality and sexual health
- religious or philosophical beliefs
- physical or mental health
- trade union membership
- political opinion
- genetic/biometric data
- criminal history
Why are we allowed to process your personal information?
Our Privacy and Cookie Policies take into account several laws, including:
- General Data Protection Regulation (EU) 2016/679
- Data Protection Act 2018
- Privacy and Electronic Communications (EC Directive) Regulations 2003
Our processing of your personal information is allowed by the laws and regulations detailed above because we have a legitimate need to carry out the processing in order to perform a contract with you or because the law requires it. We only use your information for marketing or communications purposes with your consent, which you may remove at any time.
Why we need your personal information
We may need to use some information about you:
- to deliver our services to you
- to continue to offer you customer support
- to investigate any concerns or complaints you may have
- to maintain the quality of services
- to assist with research and planning of new services
- to keep track of expenses and other service-related costs
- for employee training and HR
How the law allows us to use your personal information
There are several legal reasons why we need to collect and use your personal information. Each section of this privacy notice explains which legal reason is being used. Generally, we collect and use personal information where:
- you, or your legal representative, have given consent
- you have entered into a contract with us
- it is necessary to protect someone in an emergency
- it is required by law
- it is necessary for employment purposes
- you have made your information publicly available
- it is necessary for legal purposes
- it is necessary for archiving, research, or statistical purposes
The law gives you several rights to control what personal information we collect about you and how we use it.
Under the GDPR you have the following legal rights, these are your:
Right to be informed
Freevacy does not usually collect data from any third party or share data with anyone else, without your prior knowledge. An example of this is where your employer has booked you onto a course. Should the occasion arise where we obtained your data from a third party, (such as another training provider), we will notify you as soon as possible or at least within one month, or where we plan to communicate with you, at that first communication. If we were to share that data with someone else, we would tell you, at the latest when that data is shared.
Right to access information we hold on you
You have the right to ask if we hold any personal data relating to you and if that is the case you are entitled to receive a copy of all this information. We are also obligated to inform you about the: [how we collect and process personal data]
- The purposes of the processing
- The sorts of personal data concerned
- Any recipients or types of recipient that your personal data has been or will be disclosed to, including recipients outside the European community
- Where possible, how long your personal data will be stored, or if that is not possible, how to work out how long it will be kept
To request access, you can contact us by letter, electronically or verbally.
Note, before we can release any personal data we hold about to you, you will be required to confirm your identity.
Go to Your personal data for more details about the information we collect and process.
There are certain situations where the data we hold about you cannot be released. These include any parts of your record which contain:
- Confidential information about other people; or
- If the law believes that giving you the information may stop the prevention or detection of a crime
Right to request a correction
If any of the personal data we hold about you is incorrect, we will correct it as quickly as possible and at least within one month (unless the amount would make it impossible to do so, when we would be entitled to extend the time by up to a further two months).
Note, we will require proof that the information is inaccurate before changing it.
Right to request data is deleted
Where the following apply you may have the right to have any personal data we hold about you erased:
- Freevacy no longer needs your personal data for the purpose it was collected or processed for
- You have withdrawn the consent or explicit consent allowing Freevacy to process your personal data and there is no other legal ground for the processing
- Where you have exercised your ‘right to object’ regarding the processing for direct marketing purposes
- Freevacy had unlawfully processed the data
- The personal data should be erased for compliance with a legal obligation
Right to restrict processing
Where any of the following apply, you have the right to restrict further processing of your personal data:
- You believe the accuracy of the personal data Freevacy holds is inaccurate,
- You believe Freevacy has processed your data unlawfully, but you oppose erasure and requests the restriction of its use instead;
- Where Freevacy no longer needs the personal data, but you require it to be retained for the establishment, exercise or defence of legal claims;
- You have objected to processing regarding public interest or legitimate interests of Freevacy, where the legitimate grounds of the Freevacy do not override your interests.
Right to data portability
Freevacy does not currently have the facilities to provide your personal data in a commonly used and machine-readable format.
Right to object
You have the right to object at any time, to Freevacy processing of your personal data where,
- It relates to direct marketing purposes including any profiling
- Where processing is for scientific or historical research purposes or statistical data.
Rights relating to automated decision making and profiling
You have the right to prevent Freevacy from making any decisions based solely on automated means that could legally affect you, including any profiling.
Should Freevacy ever make a decision relating to you based on automated processing, we ensure that a human review of the decision can be made upon request. We would also supply you with any meaningful information about the logic involved in the decision making as well as the significance and consequences for you of that decision.
Freevacy work hard to secure our IT systems and your data against cyber attack. We have been awarded Cyber Essentials certification by The National Cyber Security Centre, part of GCHQ and have signed up to the ICO's "Your Data Matters" campaign.