GLW Draft Privacy Statement Version A – websites which don’t require the customer to create an account.
At Management Advantage we are committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes.
Any questions regarding this Policy and our privacy practices should be sent by email to firstname.lastname@example.org
WHO WE ARE
We are Management Advantage based at 39a Brondesbury Villas, London, NW6 6AJ
HOW DO WE COLLECT INFORMATION FROM YOU?
- We request sign up to our email newsletters via our website
- We collect your details via evaluation forms at the end of training sessions
- We collect details of your IP address when you view our website, we do this via cookies * (see definition below from Plain English Wikipedia which will be provided as a click through link.)
WHAT TYPE OF INFORMATION IS COLLECTED FROM YOU?
The personal information we collect from you might include your name, address, email address , IP address (collected via cookies), postcode and information about which pages on our website you have accessed and when. If you purchase a product from us your credit card information is not held by us, it is collected by third party payment processors who specialise in the secure online capture and processing of credit and debit card transactions, as explained below.
HOW IS YOUR INFORMATION USED?
We may use your information to:
- to carry out our obligations arising from any contracts entered into by you and us;
- seek your views or comments on the services we provide;
- notify you of changes to our services;
- send you communications which you have requested and that may be of interest
- to you.
We will hold your personal information on our systems for as long as is necessary for the relevant activity.
WHO HAS ACCESS TO YOUR INFORMATION?
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Sevice providers acting on our behalf
Any third party services or contractors we employ (to produce websites and send marketing information via email for example) that need access to data (IP addresses, email addresses) are bound by a contract that requires them to keep the information secure and not to use it for their own direct marketing purposes.** Our email database is kept securely password protected Mailchimp, you can see their privacy policies by clicking here.
We use Google analytics to see how many people have accessed our website and what pages they have spent time reading. It also tells us whether people are visiting our site as a result of search engine traffic or through links from other websites or marketing emails. Google analytics relies only on IP addresses to collect this information. You can read the Google data protection policy here.
We use a third party plugin Wordfence which scans IP addresses such that we can block access to our site from known spammers and hackers.
Our site is built in WordPress which requires the collection of IP information for any with access to update the site.
It is possible to disable cookies via your browser but it may affect the functionality of our site.
Any data from information provided by cookies is only shared with the third parties listed above.
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.
We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: email@example.com
HOW CAN YOU ACCESS OR UPDATE YOUR INFORMATION?
The accuracy of your information is important to us. If you wish to know what if any data we hold on you please email us at: firstname.lastname@example.org or write to us at: 39a Brondesbury Villas, London, NW6 6AJ.
If you wish us to delete your information from our records we will do so.
UNSUBSCRIBING FROM MARKETING EMAILS
If you unsubscribe from our marketing email list we will not send you any further emails however we will still keep your email address on file. If you wish your details to be completely deleted please email us at email@example.com., or write to us at
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.
LINKS TO OTHER WEBSITES
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
We have policies in place to help prevent data breaches. Data that we collect via our website is transmitted via an encrypted connection Any data we hold on our own computers in spreadsheet or database form is password protected.
Employees are aware that the following actions are to be strenuously avoided:
- Loss of computing devices (portable or otherwise), data storage devices, or paper records containing personal data
- Disclosing data to a wrong recipient
- Handling data in an unauthorised way (eg: downloading a local copy of personal data)
- Unauthorised access or disclosure of personal data by employees (eg: sharing a login)
- Improper disposal of personal data (eg: hard disk, storage media, or paper documents containing personal data sold or discarded before data is properly deleted)
We take measures to avoid loss of data as a result of malicious activities, which include
Hacking incidents / Illegal access to databases containing personal data
Theft of computing devices (portable or otherwise), data storage devices, or paper records containing personal data
Scams that trick our staff into releasing personal data of individuals
Failure of cloud computing cloud storage security / authentication / authorisation systems
All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:
Investigate the failure and take remedial steps if necessary
Maintain a register of compliance failures
Notify the Supervisory Authority of any compliance failures that are material either in their own right or as part of a pattern of failures
Under the GDPR, the DPO is legally obliged to notify the Supervisory Authority within 72 hours of the data breach (Article 33). Individuals have to be notified if adverse impact is determined (Article 34). In addition, we must notify any affected clients without undue delay after becoming aware of a personal data breach (Article 33).
We do not have to notify the data subjects if anonymised data is breached. Specifically, the notice to data subjects is not required if the data controller has implemented pseudonymisation techniques like encryption along with adequate technical and organizational protection measures to the personal data affected by the data breach (Article 34).
When someone is using a computer to browse a website, a personalised cookie file can be sent from the website’s server to the person’s computer. The cookie is stored in the web browser on the person’s computer. At some time in the future, the person may browse that website again. The website can send a message to the person’s browser, asking if a cookie from the website is already stored in the browser. If a cookie is found, then the data that was stored in the cookie before can be used by the website to tell the website about the person’s previous activity. Some examples where cookies are used include shopping carts, automatic login and remembering which advertisements have already been shown.
Cookies have been a problem for Internet privacy. This is because they can be used to track browsing behavior. Cookies have often been mistaken for computer programs. But cookies cannot do much on their own. They are simply a piece of data. They are occasionally called spyware or viruses, but they are not either of these.
Most web browsers allow users to choose whether to accept cookies