DATA PRIVACY NOTICE
This Privacy Notice explains the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data, and keep it safe.
- WHO WE ARE AND WHAT WE DO
Carter Noble Independent Safeguarding is a limited company that delivers a range of services, including data protection – with a DPO service – safeguarding support for schools and businesses and training courses across our areas of expertise, including court skills for social workers and other professionals.
- THE FIRST POINT OF CONTACT FOR DATA PROTECTION
If you have concerns about any data protection or privacy matter, in the first instance please contact info@carter-noble.co.uk and we will be pleased to try to rectify the issue.
- WHY WE PROCESS DATA
Carter Noble processes data so that we can conduct our business as described above. We do not use your data for any other purpose.
- LEGAL BASES FOR PROCESSING YOUR DATA INCLUDING ANY EXPLANATION OF LEGITIMATE INTERESTS
The law on data protection sets out a number of different reasons for which a business may collect and process your personal data. At Carter Noble we process data to:
(a) Comply with our contractual obligations – both in delivering our contracts and in preparing to enter a contract. This is in respect both of those we supply services to and those we engage to help us provide our services
(b) ensure that we fulfil all of our legal obligations; for example, we retain data for the required period for HMRC accounting regulations
(c) In particular circumstances, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or the interests of the data subject. In some cases, after a contract period we retain some data so that we can continue business relationships over longer periods.
We do not undertake any direct marketing or produce any “newsletters”.
- WHEN WE COLLECT DATA
Carter Noble collects data at the point that a client or customer makes contact and throughout the contract period. This may be via telephone, email or though a contact form on the website.
- WHAT DATA WE COLLECT
- Information from our website; www.carter-noble.co.uk
- Contact information including: name, address, phone number, email address
- Limited financial information so that we can pay our suppliers
- We do not collect any special category data
- WEBSITE AND THIRD-PARTY LINKS
Our website includes links to third-party websites. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from ours. Therefore, if you use these links to leave our site and visit websites operated by third parties, we cannot be responsible for the protection and privacy of any information that you provide to them. Please check these policies before you submit any personal data to these websites.
Carter Noble websites uses Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not directly identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our websites.
- SOCIAL MEDIA
Information or comment you post or disclose on Carter Noble’s social media platforms (for example, Facebook, LinkedIn, Twitter, or other social media applications) is public and will be treated as such for the purposes of this notice and Carter Noble’s use of that data. Carter Noble cannot control the use of information disclosed in such platforms. You should always take care and exercise caution when posting or disclosing information in public spaces; this includes personal information or data. Content posted in Carter Noble’s social media pages and interactive parts of the Hub, including advice and opinions, represents the views of the individuals who post that content and such individuals bear sole and exclusive responsibility for the posting of that content. Carter Noble does not necessarily endorse, support, verify, or agree with any content posted on our social media pages and forums.
- SOCIAL MEDIA WIDGETS
Carter Noble websites include social media widgets, such as the Facebook, LinkedIn, Twitter buttons and widgets, such as the “Share” button (embedded in specific articles on our Knowledge Centre). Social Media widgets are either hosted by a third party or hosted directly on Carter Noble’s website. Your interactions with these widgets are governed by the privacy policy of the company providing them. These widgets may collect (a) your IP address, (b) which Carter Noble webpage you are visiting, and (c) may set a cookie to enable the feature to function properly. Carter Noble advises anyone using these widgets to be aware of the privacy notices related to each widget.
- 10. HOW WE USE YOUR PERSONAL DATA
We process data for limited reasons; put simply, to run the business. So this might be to contact a client via email or by telephone. We do not use data except for this core purpose (except where we have given you the choice in respect of cookies on our website).
- 11. HOW LONG WE KEEP YOUR PERSONAL DATA
We retain data for no longer than is required – for example for finance information we may retain data for 6 years after the end of the accounting period so that we comply with HMRC regulations. Carter Nobel retains limited information beyond the specific contract period for up to 15 years to ensure all documents are available if required by any court in any proceedings.
- HOW WE KEEP YOUR DATA SAFE
We are aware of the need to maintain the correct and highest level security when processing your personal information. We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.
We take the following steps to maintain the security of your personal information:
- we keep all of your information in systems that are encrypted, secure and fully backed up at all times – in real time,
- We limit access to your personal information to those who have a genuine business need to know it.
- We use strong password protected systems and deploy two-factor identification in those areas that allow this
- We maintain firewalls and anti-virus software
- Any data which is accessed off site or on a mobile device is kept locked when not in use and never left unattended
Carter Noble is committed to being an environmentally aware company. As such we run a paperless office – papers are not retained unless they are required to be. This would not include any information which contains personal identifiable data.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- WHO WE SHARE YOUR DATA WITH
We sometimes share your personal data with trusted third parties which act only on our instruction (known as “data processors”).
Data processors might be, for example, those companies who process or store data for us:
Where we share information with these companies or individuals we make sure that they also keep your data secure and that they also protect your rights. To this end we make sure that:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them or where their terms and conditions of processing contain the correct data processor clauses under UK GDPR
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Sharing your data with third parties for their own purposes (“joint controllers”) eg HMRC, accountants, legal advisors:
We will only do this in very specific circumstances, for example:
- With your consent
- Where we have a contract in place with the other party
- Where we are obliged to share the information for legal reasons
- WHERE YOUR DATA IS PROCESSED
We do not routinely transfer data outside of the UK/EEA; we use servers based in the UK.
We may pass personal data such as your name and email address via other services providers that we use, for example to send communications via email.
Your personal data will remain in the EEA/UK or countries considered by the EU to have equivalent policies such as Jersey, Guernsey, Switzerland, New Zealand and Canada. Any companies based outside of these “adequate” countries, for example in the USA such as Microsoft or Apple, have certified up to date and valid Standard Contractual Clauses to protect the data and data subjects with equivalence to those protections afforded by the UK or EU.
- YOUR RIGHTS AND WHO TO CONTACT
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| To be forgotten | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object |
The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
If you would like to exercise any of those rights, please contact us: info@carter-noble.co.uk
- OTHER RIGHTS
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. You can do this by contacting info@carter-noble.co.uk
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We will then stop processing your information unless we believe we have a legitimate overriding reason to continue processing.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
Your right to contact the ICO
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
You also have the right to take to seek a judicial remedy.