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Privacy Notice – General

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PRIVACY POLICY: GENERAL

1.    Introduction

1.1     At Strategic North we are committed to maintaining the trust and confidence of the visitors to our website, anyone who discloses their details to or contacts us and anyone we contact who we think might be interested in what we do and the services that we offer. In particular, we want you to know that Strategic North is not in the business of passing on your personal information to other companies and businesses for marketing purposes. We just don’t do that sort of thing. But just in case you want to find out more, in this Privacy Policy, we’ve provided lots of detailed information on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose it to others, how we keep it secure and how you can get in touch to delete or amend any of your personal information.

 

2.    Type of data we collect

2.1     We operate a strict data minimisation approach at Strategic North so we only collect and process data that is necessary for us to effectively run and manage the projects we do, including occasionally sharing information about who we are and what we do.

2.2     We also only keep it for as long as it is needed to do this. Not a moment longer. Once it isn’t essential we remove it from our systems.

2.3     Some of the data we collect identifies you personally, such as:

  • your name
  • email
  • phone number
  • where you work

2.4     Whilst other information such as the cookies we collect and process when you visit our website provides non-personal information such as your IP address, browser details or other technical information. To find out more about how we use and manage cookies click here cookies@strategicnorth.com

 

3.    What we do with your data

3.1     We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

(a) Where we need to perform the contract we have entered into with you.

(b) Where we need to comply with a legal obligation.

(c) Where we have a legitimate business interest.

 

4.    With whom might we share your data

4.1     When someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. We use this data to improve our site and to optimise and personalise your experience using it.

4.2     We may also use data to keep you informed on who we are, what we do and any services that we believe might be of interest to you. We only ever aim to contact people who we believe would be interested in and would benefit from knowing this information. If at any point you are contacted and you feel this is not appropriate and/or do not wish to be contacted again, we aim to make it as quick and easy as possible for you to be excluded from any further contact. Any such email we send always including a short message including a prominent unsubscribe link.

4.3     Any data we do hold is on basis of legitimate business interest or as part of our contractual

 

5.    How do we protect your data

5.1     We have put in place measures to protect the security of your information. Details of these measures are available in the data protection policy available at strategicnorthcom.

5.2    Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

5.3    We only ever use IT platforms that are GDPR compliant.

5.4    We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Head of Marketing and Head of Finance and Business Operations.

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

 

6.    How long we keep your data

6.1     We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are confirmed below. 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.

6.2 .   In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

6.3     We will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require. This includes requiring third parties to delete such data where applicable.

6.4     The documentation retention periods which we will apply in relation to certain data are as follows, but we will from time to time record separately the periods for which we will retain other data not covered by the headings below (documentation will be retained for a slightly longer period to ensure that the relevant period has expired and destruction or erasure of records may take place periodically meaning that records will be retained slightly longer than detailed):

(a) Personal data which includes your name, email address, phone number and your place of work – 2 years.

(b) Non personal information includes you IP address, browser details and other technical information – 2 years.

 

7.    Your privacy rights and who to contact about them

7.1     Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

7.2     Your rights in connection with personal information
Under certain circumstances, by law you have the right to:

(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

(d) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

(e) Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

(f) Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Head of HR & Head of Finance and Business Operations in writing.

7.3     No fee usually require
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

7.4     What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

7.5     Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Head of HR & Head of Finance and Business Operations. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

8.    Changes to our privacy policy

8.1     We monitor our privacy policy regularly and may update it at any time. When we do will post a notification on the home page of our website. We encourage you to check this page regularly to keep up to date on how we are processing and protecting your data.

8.2  This policy was last updated on May 24th 2018

 

9.    Acceptance of our terms

9.1     By using our website you signify acceptance of the terms of our policy. If you do not agree with this policy please don’t use our site.

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