Privacy Policy

Introduction
This privacy notice provides you with details of how we collect, store and process your data. It should be read in conjunction with the contract that controls our business together and our general terms and conditions.

The privacy and handling of data that identifies living individuals is important. I will operate a ‘by default and by design’ set of procedures. I will be acting in the capacity of data controller and data processor. It is important that the data is accurate and up to date so if any information you have provided changes than please update me. 

Data Collected
The data I may collect, store and process includes the following types:

Identity data, including but not limited to, your full name, title.

Contact data, including but not limited to, billing address, delivery / site address, email address, phone numbers.

Financial data, including but not limited to, your bank account details, transactions resulting from the work we carry out for you.

Communications data, including but not limited to, email communications

Please note that as part of our contractual relationship I may collect, store and process personal details of other individuals in your organization and you must have obtained permission either by contract or consent with them for us to do that.

I do not collect, store or process sensitive data as defined by the regulation.

If you fail to provide data concerning yourself or others in your organization, then we will not be able to provide the services indicated in the contract. This would result in a temporary or permanent loss of service or services and may result in additional time charges. If this happens I will notify you.

How I collect data
Direct interaction: Data you provide via email, letter, phone call

From Third Parties: from accounts that you access to manage on your behalf. The Companies House website (if your business operates as a limited company).

How I process collected data
Your data will only be processed when there is a lawful reason to do so.

I have determined that the main lawful reasons will be:

in order to meet the obligations of the contract that exists between us
where we need to comply with a legal or regulatory obligation
for legitimate interests.
Further processing may become necessary if we need to transfer data to a third party. If this becomes necessary you will be informed of this activity.

I do not normally rely on consent as a lawful basis for processing however we will obtain it from you if a processing reason arises. Where consent has been granted it may be withdrawn at any time in writing by emailing the address shown in section 1 above.

I will only process your data under one of the lawful bases listed above.

The data provided will be held on one or more systems whether on premise or off premise (cloud based).

The data used for support will be stored whilst the contract is in place and for a maximum of twelve months after the contract ends. 

I will process the data on individuals in your organization in order to provide the services described in the contract between our organizations.

Your Legal Rights
Under certain circumstances, you have the right to rectification, erasure, restriction, objection, if you deem, and it is proven, the data we hold is incorrect.

You have the right to data portability

If you wish to exercise any of the rights set out above, please email me at hello@shawnafullington.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, Imay refuse to comply with your request in these circumstances.

I may need to request specific information from you to help confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

I try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. 

Your personal data will not be subjected to automated decision-making activities.

Disclosures of your personal data
I may have to share your personal data with the parties such as Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

I require all processors and third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Data Security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Data Retention
I will only retain your personal data for as long as necessary to fulfill the purposes it is collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I 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.

By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. This data will therefore be retained for seven years to allow us to respond to a ‘last minute’ request.

Technical data will be kept for one year beyond the date on which the last processing occurred.