GDPR DATA PRIVACY NOTICE FOR CLIENTS
PA2day Ltd (“We”) are committed to protecting and respecting your privacy.
This Notice sets out the basis by which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – A natural person
Categories of data: personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories of personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
PA2day Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Clovalley House, 6 Cyprus Avenue, Belfast, BT5 5NT. For all data matters contact Alyson McNutt, Data Protection Officer (DPO), via email at firstname.lastname@example.org
On occasions we also act as a Data Processor for clients.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To provide our administration, note-taking and transcription services
- To maintain our business accounts and records
- To update you on our services
You may give us information about you by filling in forms on our website at www.pa2day.co.uk or by corresponding with us by phone, email or otherwise. This includes information you provide when you request information about our services.
4. The categories of personal data concerned
We will only use your personal or special data for the purpose for which it was collected and when the law allows us to.
With reference to the categories of personal data described in the definitions section, we may process the following categories of your data dependent on the type of services you require:
- Personal data – contact details, financial information and bank details, date of birth, marital status, National Insurance number, tax details, references, qualifications, employment history and details, insurance details, assets and liabilities, family member details, lifestyle and social circumstances, goods and services, photographic ID, nationality and residential history, citizenship and visas.
- Special categories of data – racial or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, physical or mental health, sexual life or orientation, genetic data, biometric data, offences and alleged offences, criminal proceedings, outcomes and sentences.
5. What is our legal basis for processing your personal data?
a) Personal data (Article 6 of GDPR)
Our lawful basis for processing your general personal data:
- Processing necessary to meet our contractual obligations in relation to the performance of our contract with you to provide professional services, or steps to enter into such a contract.
- Where it is necessary for our legitimate interests (or a third party) and your interests or fundamental rights or freedoms do not override those interests.
b) Special categories of personal data (Article 9 of GDPR)
Assignment dependent, our lawful basis for processing your special categories of data:
- In limited circumstances with your consent.
- The personal data has been manifestly made public by you.
- For the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity.
- For reasons of substantial public interest on the basis of EU or Member State law.
- For reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional.
- For the reasons of public interest in the area of public health.
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential. We will not share personal data with any third-party organisations for the purposes of marketing.
We sometimes need to share the personal information with a small team of contracted associate staff. Where this is necessary we are required to comply with all aspects data legislation. The following is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons:
Where necessary or required we share information with:
- Contracted Associates
- Suppliers and Service Providers (Secure Data Storage, HR Consultants, IT Suppliers)
- Courts and Tribunals
7. How long do we keep your personal data?
We will only retain your personal data for as long as is necessary to fulfil the purposes for which we collected it including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider 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 process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Retention periods for different types of your personal data are detailed in our Data Retention and Destruction Policy which is available on request from the DPO.
In some circumstances we 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.
We will securely destroy your data once we are no longer required to retain it. We use the following criteria to determine how long to retain your personal data.
|To provide professional services||Contact Details – End of customer relationship
PA and Administration services
Minute-taking and Note-taking service
Audio transcription service
|To maintain our business accounts and records||Financial Information and Accounts – 6 years|
|To inform you of news, services or activities that may be of interest to you||End of customer relationship, on notification that the individual has left the organisation or on request to withdraw|
8. Providing us with your personal data
We require your personal data as it is a contractual requirement necessary to enter into a contract for the provision of professional services.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of data abroad
We do not transfer personal data outside the Economic European Union.
11. Automated decision making
We do not use any form of automated decision making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. Changes to our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be notified to you.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact the DPO via email at email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.