Envisage ("We") are committed to protecting and respecting your privacy.
This policy (together with our, Data Protection Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.envisagetraining.co.uk you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Envisage of 80 Church Street, Old Glossop, Derbyshire, SK13 7RN.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site www.envisagetraining.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph and basic health information.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them which may include your contact details, information about your needs and other related personal data.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Envisage or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE WE STORE YOUR PERSONAL DATA
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
1. POLICY STATEMENT
1.1 Everyone has rights with regard to the way in which their personal data in handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
1.2 Data users are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy may result in disciplinary action.
2. ABOUT THIS POLICY
2.1 The types of personal data that Envisage (We) may be required to handle include information about current, past and prospective suppliers, customers and others that we communicate with. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 1998 (the Act) and other regulations.
2.2 This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.
2.3 This policy does not form part of any employee's contract of employment and may be amended at any time.
2.4 This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
3. DEFINITION OF DATA PROTECTION TERMS
3.1 Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
3.2 Data subjects for the purpose of this policy include all living individuals about whom we holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
3.3 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
3.4 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.
3.5 Data users are those of our employees whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.
3.6 Data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on Envisage’s behalf.
3.7 Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
3.8 Sensitive personal data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.
4. DATA PROTECTION PRINCIPLES
Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:
5. FAIR AND LAWFUL PROCESSING
5.1 The Act is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.
5.2 For personal data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the Act. These include, among other things, the data subject's consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, additional conditions must be met. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.
6. PROCESSING FOR LIMITED PURPOSES
6.1 In the course of our business, we may collect and process the personal data set out in the Schedule. This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
6.2 We will only process personal data for the specific purposes set out in the Schedule or for any other purposes specifically permitted by the Act. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.
7. NOTIFYING DATA SUBJECTS
7.1 If we collect personal data directly from data subjects, we will inform them about:
7.2 If we receive personal data about a data subject from other sources, we will provide the data subject with this information as soon as possible thereafter.
7.3 We will also inform data subjects whose personal data we process that we are the data controller with regard to that data.
8. ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
9. ACCURATE DATA
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
10. TIMELY PROCESSING
We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
11. PROCESSING IN LINE WITH DATA SUBJECT'S RIGHTS
We will process all personal data in line with data subjects' rights, in particular their right to:
12. DATA SECURITY
12.1 We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
12.2 We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
12.3 We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
12.4 Security procedures include:
13. TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE EEA
13.1 We may transfer any personal data we hold to a country outside the European Economic Area ("EEA"), provided that one of the following conditions applies:
13.2 Subject to the requirements in clause 12.1 above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.
14. DISCLOSURE AND SHARING OF PERSONAL INFORMATION
14.1 We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
14.2 We may also disclose personal data we hold to third parties:
14.3 If we are under a duty to disclose or share a data subject's personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
14.4 We may also share personal data we hold with selected third parties for the purposes set out in the Schedule.
15. DEALING WITH SUBJECT ACCESS REQUESTS
15.1 Data subjects must make a formal request for information we hold about them. This must be made in writing. Employees and or consultants working on our behalf who receive a written request should forward it to Us immediately.
15.2 When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
15.3 Our employees and or consultants will refer a request to their line manager for assistance in difficult situations. Employees and or consultants should not be bullied into disclosing personal information.
16. CHANGES TO THIS POLICY
We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.