At Straightforward Consultancy, we understand that your privacy is important and are compliant with the General Data Protection Regulations. We will treat any personal data which we hold, or that you provide to us as confidential and it will only be used to enable us to provide our services and maintain appropriate company records. We promise to look after your personal data and we will never sell this information to any other party.
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Straightforward Consultancy takes data protection and client privacy very seriously and has always taken great care to ensure that both physical and electronic records of client information are maintained in a secure environment or disposed of securely, and this will continue under the new General Data Protection Regulations (hereafter referred to as GDPR).
All of the employees within Straightforward Consultancy are aware of GDPR and that it requires a higher standard than the Data Protection Act 1998, with which Straightforward Consultancy were also compliant.
As we offer a business to business (B2B) service to our customers, we do not hold sensitive data, such as personal email addresses, home addresses, home phone numbers or personal mobile phone numbers, however we do hold what is classified as “personal data”, even though this is limited to individual’s names, business email addresses, business addresses and business phone numbers.
We have updated our current privacy notice which is posted on our website www.straightforwardconsultancy.co.uk. Under the new regulations, we would be classified as a data controller as we determine the use of the personal data which we collect, although this is limited and used only to allow us to carry out the services we offer to our customers or potential customers with whom we have historically been in contact to offer our services. We will never sell or pass on customer data to other companies for processing or commercial use and do not currently carry out any direct email marketing campaigns using prospective customer data which may be available commercially. Our business development is generally conducted on a case by case basis via sales leads or referrals and this will continue as before, whilst being mindful of the GDPR regulations.
We have reviewed our procedures to ensure that our policies cover individuals’ rights.
Should one of our customers approach Straightforward Consultancy with a subject access request, we will be able to advise them what information we hold on file (which will be held in separate files per customer) and more importantly, our systems will tell us exactly where this information is located.
As per the guidelines laid out by the Information Commissioners Office, our lawful basis is:-
(b) Contract: the processing is necessary for a contract you have with an individual, or because they have asked you to take specific steps before entering into a contract.
Given the nature of our business and that we are in contract with our business customers to offer a service, we have reviewed the lawful basis for consent and believe that formal request for consent is not necessary as per below
(b) Contract: the processing is necessary for a contract you have with an individual, or because they have asked you to take specific steps before entering into a contract.
We do not have any engagement with children in our business, we are dealing business to business and dealing with employees of UK businesses.
We have our own IT equipment where data is stored and all computers and mobile devices are password protected. We also back up our business data online and on premise via physical back-up drives. We operate in a secure and locked environment and have a record of what IT equipment we use and what have on site. We use leading companies including Apple, Microsoft and Carbonite to store and back up our business data and have checked that these organisations are GDPR compliant and that they will automatically notify us should they suffer a data breach which affects our own customer data. We will in turn notify the ICO if we suffer a data breach.
As we are not a) deploying new technology, b) running profiling operations or c) processing on a large scale, special categories of data
We are a micro-SME and do not consider our business large enough to warrant the designation of a Data Protection Officer, however our lead contact on GDPR will be Andrew Cliff
Straightforward Consultancy operates in the UK alone and provides services for UK registered businesses so Article 29 does not apply.
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"It is a pleasure to work with Andy who is professional, driven and easy to get on with” Paul Critchlow, Managing Director, Distinctive Medical Products, Runcorn
