Herrington Consulting Ltd (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on 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 – 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 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.
Who are we
Herrington Consulting Ltd is the data controller. This means we decide how your personal data is processed and for what purposes.
Our contact details are: Unit 6 & 7 Barham Business Park, Elham Valley Road, Barham, Kent, CT4 6DQ or firstname.lastname@example.org.
For all data matters contact Claire Herrington on email@example.com or 01227 833855.
The purpose(s) of processing your personal data
We use your personal data for the following purposes:
We collect your name, company name (if applicable), address, telephone number and email address. This information is necessary in order for us to fulfil our contractual obligations to you as a client and as such there is a ‘Contract’ lawful basis under GDPR for processing this data. This data is only used for the requirements of the work commissioned by you and for the duration of the contract.
Data is stored on our secure internal database used for project administration and invoicing. This database has restricted access. These details may also be used to verify the project commissioned should you require support or request details of our services or invoicing from us at some point in the future.
We never collect any ‘special’ categories of data as defined by GDPR (e.g. race, political, religion, trade union, genetic, health etc. etc.)
We never share your information with Third Parties or use your data for marketing purposes.
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data [name, company name (if applicable), address, telephone number and email address and for Suppliers: Bank details including sort code and account number]
We have obtained your personal data from you or your representative, either by email or completed data sheet online at www.herringtonconsulting.co.uk.
What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Quotation, Schedule of Prices, Terms and Conditions, Privacy Notice are accepted with the written commission of the data subject and/or representative.
Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with the persons assigned to your project that is appropriate for adhering to the agreed contract.
How long do we keep your personal data?
[Clients] We keep your personal data for the duration of the contract and as long as is necessary due to the nature of our reports and PI Insurance. Your details are securely archived on completion of the contract in the event of the report needing to be updated in the future when there are changes in policy or the development is sold and requires us to produce letters of reliance in line with our PI Insurance.
[Suppliers] Your personal data is reviewed at the beginning of our business year (June 1st). Any named contacts and contact details are deleted when we are no longer using your services and your account has been dormant for 2 years or more.
Providing us with your personal data
We require your personal data as it is a contractual requirement, or a requirement necessary to enter into a contract.
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).
Transfer of data abroad
We do not transfer personal data outside the EEA.
Automated decision making
We do not use any form of automated decision making in our business
If we wish to use your personal data for a new purpose, not covered by this Data 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.
How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA REPRESENTATIVE on firstname.lastname@example.org or 01227 833855.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners 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.