GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND BUSINESS PARTNERS
Susan Hart, nutrition coach (“I”) is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data I collect from you, or that you provide to me, will be processed by me. Please read the following carefully to understand my views and practices regarding your personal data and how I 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.
2. Who I am?
As Susan Hart, nutrition coach I am the data controller. This means I decide how your personal data is processed and for what purposes. My contact details are: firstname.lastname@example.org 07946 301338.
3. The purpose(s) of processing your personal data
I use your personal data for the following purposes:
Invoicing or contacting you re: my courses, workshops and sessions that I offer.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, I process the following categories of your data:
- Personal data: name, address, telephone numbers and email addresses.
I have obtained your personal data from information you have supplied to me.
5. What is my legal and lawful basis for processing your personal data?
Processing is necessary for the performance of a contract with you the data subject or to take steps to enter into a contract.
a. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be not be shared with anyone, unless legal authorities need access to it.
b. How long do I keep your personal data?
I keep your personal data for no longer than reasonably necessary in order to keep you informed of up and coming relevant events and to invoice you.
c. Providing me with your personal data
I require your personal data as it is a requirement necessary to enter into a contract.
d. 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 I hold about you;
- The right to request that I 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 request that I 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).
6. Further processing
If I wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then I 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
8. How to make a complaint
To exercise all relevant rights, queries or complaints please contact me, Susan Hart on 07946 301338
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.