This policy explains how A Stewart’s View uses, stores and protects any personal data it manages through the provision of its services.
A Stewart’s View takes its obligations to any personal data held very seriously and has updated this policy to accommodate new EU General Data Protection Regulation (GDPR) that come into effect on 25 May 2018.
I may update this policy from time to time to provide additional information or clarity. This page will be the master copy of my policy, and I encourage users to check for any updates regularly.
I intend to try and use plain English as far as possible under my requirements for this policy. Any use of ‘us’, ‘we’ or ‘our’ etc. refers to A Stewart’s View. Any use of ‘you’, ‘your’ or ‘you’re’ etc. might refer to the readers of this blog. There are some legal terms used out of necessity but please get in contact if you require clarification on any of this policy.
To contact me regarding this policy, please refer to the Contact Me page.
GENERAL DATA PROTECTION REGULATION (GDPR)
The General Data Protection Regulation (GDPR) takes effect from 25 May 2018. GDPR is an evolution of the existing Data Protection Act (DPA) and Data Protection Directive. It is intended to give all of us greater visibility and control of our personal information (referred to as personal data).
Personal data is defined as, “… ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.”
What this means is any information an organisation holds that could be used to identify a person, counts as personal data.
You can find out more about GDPR and how the Information Commissioner’s Office (ICO) applies it to organisations on their website www.ico.org.uk
TYPES OF INFORMATION
Information, or data, that we hold is done so on a consent or legitimate interests basis, meaning that we hold and use information based on your permission (consent) to do so, such as providing your email address and name when you sign up to our email newsletter, or on the requirement for that information to provide our services (legitimate interests).
There are three main types of information A Stewart’s View holds to provide services to you:
The information you give us
You provide us with information when you use our services. This may be an application to join A Stewart’s View newsletter. In all cases, you choose to provide the information requested so that we may provide the service.
Information will typically be provided to us via a form. This form may be accessed online, such as a contact form.
Information that technology gives us
Information is sometimes automatically passed between your chosen technology andA Stewart’s View technology by accessing our digital services. The most common usage is website analytics and browser cookies.
Your web browser automatically passes information about itself and your device (computer/mobile etc.) to any internet location you visit. Your browser has specific settings you can adjust to limit or increase these options.
This information is often referred to as metadata and is information including log data, information passed by your web browsers like IP address or other web browser information; device information, like what type of computer or mobile device accessed our website; location information, such as an approximate location while accessing our website.
We maintain an active email newsletter and bulletin service to opted-in users and we usually receive information, such as a confirmation when you open an email, when the email is opened, and any links clicked—but only if your technology and services permit it.
This service operates an independent op-out, meaning you may unsubscribe without having to contact us.
THE CONTROLLER OF PERSONAL DATA
Any personal information provided to or gathered by A Stewart’s View is controlled by Stewart Wilms-Harvey.
To communicate with me, please refer to the Contact Me page.
HOW INFORMATION IS USED
We use any information you provide to us to fulfil the service or services related to your data.
The core uses of personal data held by A Stewart’s View are:
- To provide, update, maintain and improve my services
- As required by law, legal process or regulation
- To communicate and respond to requests, comments and questions
- To send service emails and other communications essential to providing membership and services
- For billing, account management and other administrative matters
- To maintain security and standards
In addition to the core purpose we use data for, we may also use the information to analyse or profile users to fulfil legal obligations, reporting obligations and to maintain and improve my services.
This may include:
- We may use data to analyse our services, e.g. satisfaction surveys and programme evaluation surveys to see how we are doing and take on board feedback
- We may profile data on a geographic basis, e.g. we may look at whether a service will qualify for funding or programme access due to relevant geographic criteria
- We may profile data on age, gender or ethnicity, e.g. we occasionally seek to understand our membership demographics to improve our offering and complete our annual reporting
- We may profile data for aggregated statistics to complete reports, e.g. we are often required to complete annual reports for programmes we run as a contractual obligation.
GDPR provides certain rights for individuals. These are how they apply to A Stewart’s View :
The right to be informed – the core purpose of this policy; we aim to tell you about the collection of personal data.
The right of access – you have access to your personal information (often called a “data subject access request”). This enables you to ask for a copy of the personal information we hold about you. This is normally free but please note that, as per ICO guidelines, an administration fee may apply, “when a request is manifestly unfounded or excessive, particularly if it is repetitive.”
The right to rectification – this is the right to have corrections made. This a shared obligation between us to keep personal data as up to date as is practical.
The right to erasure – 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).
The right to restrict processing – This enables you, where appropriate, to ask us to suspend the processing of personal information about you. For example, if you are checking the accuracy of information we hold.
The right to data portability – in clearer words, the ability for you to take personal data from us to an alternative supplier. Less relevant to our operations but the right remains.
The right to object – where we are using a legitimate interest basis, and there is something which makes you want to object to processing on these grounds. This may mean we are unable to provide some services to you.
Rights about automated decision making and profiling – automated decision-making takes place when an electronic system uses personal information to decide without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
SECURITY AND WHERE INFORMATION IS STORED
A Stewart’s View takes every reasonable precaution to ensure any data we hold is secure and stored according to GDPR.
The following details explain the groupings for data storage; the technology involved and location.
A Stewart’s View website is hosted on a third party hosting service. No data is held locally.
A Stewart’s View will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
Like the majority of websites, A Stewart’s View website uses modern technology and data provided by you and your browser to try and provide the best service and experience we can.
Cookies may be used on our website. A cookie is a very small text file that is placed on your computer’s hard drive when accessing a website and it collects standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.
If you access A Stewart’s View website you agree to be bound by the conditions in this legal message and further agree that the Federal Court of Australia shall have exclusive jurisdiction in respect of any dispute arising from this legal message.
The copyright in the material contained in A Stewart’s View website belongs to Stewart Wilms-Harvey. All rights are reserved. Except solely for your own personal and non-commercial use no part of this website may be copied, performed in public, broadcast or adapted without the prior written permission of Stewart Wilms-Harvey.