CRD Consulting Ltd Privacy Notice Confidential May 2022
CRD Consulting Ltd Privacy Policy
1. INTRODUCTION
The purpose of this Privacy Policy is to describe the types of information that we collect from you when you contact us, sign up to our mailing lists or use our website and social media sites, and to explain how we use that information. This is in line with General Data Protection Regulation (GDPR) which came into effect 25 May 2018.
This Privacy Policy refers to the storage and usage of all data, however, it is only personal data not available in the public domain which is covered by the new GDPR legislation – not, for example, work contact details or role information.
This notice includes any information you may provide through our site when you sign up to our newsletter, register for an event, purchase tickets for an event, take part in a survey or take part in a competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
CRD Consulting Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
Our full details are:
Full name of legal entity: CRD Consulting Ltd
Email address: michelleconway@crdconsulting.co.uk
Postal address: CRD Consulting Ltd, 9 Bankers Brae, Balfron, Glasgow, G63 0RF
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at michelleconway@crdconsulting.co.uk
2. WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
CRD Consulting Ltd Privacy Notice Confidential May 2022
We may process certain types of personal data about you as follows:
1. Identity Data may include your first name, last name, username and title.
2. Contact Data may include your billing address, delivery address, email address and telephone numbers.
3. Financial Data may include your bank account and payment card details.
4. Transaction Data may include details about payments between us and other details of purchases made by you.
5. Profile Data may include purchases or orders, your interests, preferences, feedback and survey responses.
6. Usage Data may include information about how you use our website, products and services.
7. Marketing and Communications Data may include your preferences in receiving marketing communications from us.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data, however, if the data is not linked to your personal data then it is not classed as personal data in itself.
Sensitive Data
We need to collect the following sensitive data about you in order to deliver our services including organising events on rare diseases and ensure the safety and comfort of all attendees.
The sensitive data may include information about your dietary requirements and accessibility requirements, occasionally health-related data.
We require your explicit consent for processing sensitive data, so when you submit your details, we will include a statement asking for your explicit consent to process this data. There will be an unticked check box for you to check to indicate you have read, understood and accept this statement and give us explicit consent to process your sensitive data.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract. We may have to cancel a service you have ordered but if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
3.1 Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email, social media or otherwise, including when you:
CRD Consulting Ltd Privacy Notice Confidential May 2022
a. order our services;
b. subscribe to our services or publications;
c. request resources or marketing be sent to you;
d. enter a competition, promotion or survey; or
e. give us feedback
f. post information on social media
3.2 Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
a. technical data from the following parties:
b. analytics providers such as Google based outside the EU;
c. advertising networks such as Facebook based outside the EU;
d. search information providers such as Google based outside the EU;
3.3 Contact, financial and transaction data from providers of technical, payment and delivery services such as PayPal, Eventbrite, Universe, Easyfundraising, Just Giving and Fit4Change based outside the EU;
3.4 Identity and contact data from publicly availably sources such as Companies House and the Electoral Register based inside the EU;
a. Email list provider based outside the EU;
b. Data on anti-spam protector based outside the UK; and
c. Accountancy details held by accountant, based in the UK.
Cookies
What's a cookie?
A "cookie" is a piece of information that is stored on your computer's hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
How do we use cookies?
We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.
CRD Consulting Ltd Privacy Notice Confidential May 2022
Cookies are either:
a. Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any personal data from your computer; or
b. Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
Cookies can also be categorised as follows:
a. Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
b. Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
c. Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
a. Where we need to perform the contract between us.
b. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c. Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at michelleconway@crdconsulting.co.uk or by clicking unsubscribe at the bottom of each of our marketing emails.
CRD Consulting Ltd Privacy Notice Confidential May 2022
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at michelleconway@crdconsulting.co.uk if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the list below.
We may use your information to:
• Administer your membership, product or the service you have signed up for.
• Provide information to you.
• Inform you of news and events in the field of genetic, rare and undiagnosed conditions.
• Offer you the opportunity to take part in research or to inform you of related research taking place.
• Inform you of sponsor organisations work or related businesses.
• Ask for your opinion or feedback.
• Promote campaigns we are running.
• Invite you to local events.
• Send you newsletters and e-news.
• Offer you the opportunity to take part in research or policy work.
Social media and other websites
Although our social media channels and Facebook groups are monitored regularly by staff, we have no control over information you or others may submit, post or share on social media or other websites – even where we link to them from our own website or they link to our website. When you use these sites you do so in accordance with the separate terms and conditions and policies of these sites.
Where your data is stored
We keep your data stored using SharePoint site which is password protected. All data that has not been anonymised is stored in a controlled folder with restricted access. Access is determined by Michelle Conway and only granted on an as required basis for the specific processing purpose. Once access is no longer needed, access will be revoked.
For research projects we store your survey data on a password protected Microsoft 365 Survey account, accessible only by CRD Consulting Ltd staff.
CRD Consulting Ltd Privacy Notice Confidential May 2022
Marketing communications
You will receive marketing communications from us if you have:
a. requested information from us or services from us; or
b. if you provided us with your details and ticked the relevant box at the point of entry of your details and consented for us to send you marketing communications; and
c. in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at michelleconway@crdconsulting.co.uk at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at michelleconway@crdconsulting.co.uk.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
a. Service providers who provide IT and system administration services.
b. Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
c. HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
d. Mailchimp, Eventbrite and Universe, to allow us to send newsletters, invites and information about upcoming events.
CRD Consulting Ltd Privacy Notice Confidential May 2022
e. Glisser, to provide an accessible event experience, to collect ROI (Return on Investment) data and to give responses to attendee questions to speakers.
f. Survey Monkey and Microsoft 365 Forms to allow us to collect feedback about our events.
We require all 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. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
It is possible that some of our third parties service providers will be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. This will be for the purpose of supporting your attendance at upcoming events.
Whenever we transfer your personal data out of the EEA, at least one of the following safeguards will be adopted:
a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
b. Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
c. Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at michelleconway@crdconsulting.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We 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, we 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.
We 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.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
CRD Consulting Ltd Privacy Notice Confidential May 2022
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.
CRD Consulting Ltd has identified all the personal data that it processes and recorded it in its Data Inventory Schedule. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. This will be stored within a secure, password protected folder on the CRD Consulting Ltd SharePoint site separate from the live data we use for processing your information.
In some circumstances you can ask us to delete your data: see below for further information.
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.
9. YOUR LEGAL RIGHTS
Under UK GDPR, you have rights in relation to your personal data. These include:
• the right to be informed.
• the right of access.
• the right to rectification.
• the right to erasure (also known as the ‘right to be forgotten’).
• the right to restrict processing.
• the right to data portability.
• the right to object; and
• rights with respect to automated decision-making and profiling.
You can see more about these rights at: Your data matters | ICO
If you wish to exercise any of the rights set out above, please email us at michelleconway@crdconsulting.co. and mark it for the attention of the Data Controller.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us 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. We
CRD Consulting Ltd Privacy Notice Confidential May 2022
may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. THIRD-PARTY LINKS
CRD Consulting Ltds website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
CHANGES TO OUR PRIVACY POLICY
We regularly review and update this policy to make sure it is accurate and simple to understand. This policy was last updated 5th December 2023.