Keeping your personal data safe
‘Data Protection Law’: Our data is UK-based and subject to data protection law in the UK and any and all other laws and regulations enacted in the UK in implementation, amendment or replacement of the foregoing, and all other applicable laws, regulations and regulatory guidance in force from time to time. In cases where this is not true, data transfers are made in accordance with the requirements of the regulation (EU) 2016/679 (the General Data Protection Regulation or “EU GDPR”) and may be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA.
Who are we?
- What personal data do we collect?
- Why do we collect personal data?
- How we protect your personal data
- Keeping your personal data secure
- Sharing your personal data
- Retention of your personal data
- Changes to your personal data
- What rights do you have?
- How do I exercise my rights?
- Contacting Us
- How to make a complaint
What personal data do we collect?
What is personal data?
Personal data is any data that identifies you, as an individual. This could include your name, address, email address or even information about your needs or circumstances.
If you are a client – We may collect and process relevant personal data, which you provide to us when you get in touch by any means in relation to our services, to provide us with instructions or to seek advice or when you subscribe to our mailing list.
If you are a supplier – We may collect and process relevant personal data in order that we are able to receive your services, process and pay your invoices.
If you are a web user – We capture certain data about how you use our website using cookies and similar technology. Cookies are tracking technology which collect information such as details about your computer system and details of your visits to our website. This tells us about how you use our services and your preferences etc. This is more fully described in our Cookies Policy, which can be accessed here.
If you are a workseeker – We may collect and process personal detail you provide to help us to help you secure a position with Navigator.
We also collect personal data that you voluntarily provide when you contact us with queries or complaints.
Data from other sources
We may also collect personal data from other parties who have obtained your permission to share your personal data with us, such as your employer, if applicable.
Special category personal data
We may process also special category data of clients and third parties as is necessary to provide our services or for the establishment, exercise or defence of legal claims.
This includes the following personal data revealing:
- racial or ethnic origin
- political opinions
- religious or philosophical beliefs
- trade union membership
- the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person
- an individual’s health
- a natural person’s sex life or sexual orientation
- criminal convictions or offences
We ensure that we meet all legal requirements in relation to the collection, use and storage or any special category personal data including any additional protections or measures that may be required.
Why do we collect personal data?
Data protection law permits us to collect, use and store your personal data on a limited number of grounds. The main grounds we rely on are:
- Where it is necessary for our/your legitimate business interests and/or those with whom we share your personal data as described in this policy and your interests and fundamental rights do not override those interests;
- To improve our services and our website and to help us provide the best service possible;
- Where it is necessary to perform the contract we have with you (or, where applicable, your employer) or to provide you with our services;
- In order to comply with a legal or regulatory obligation, for example where are required to check our clients’ identity under the anti-money laundering laws; or
- Where you have given us express consent in relation to marketing or for you to subscribe to our newsletters.
How we protect your personal data
The Data Protection laws are clear: the protection of personal information is paramount. As a result, Navigator must meet certain clear and robust obligations. In short, your personal data must be:
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Used lawfully, fairly and in a transparent way;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely and protected against unauthorised or unlawful use and against loss, destruction or damage using appropriate technology and procedures.
Keeping your personal data secure
We have technical and operational security policies and procedures in place to protect the personal data we collect, use and store, against unauthorised or unlawful access or disclosure, improper use, alteration and unlawful or accidental destruction or loss.
The measures we have in place include:
- We enforce a clear desk policy and do not use or retain paper files and records except where this is necessary;
- Our staff are well trained in the requirements of the data protection laws; and
- We use all appropriate encryption and password protection on our systems.
All personal data we collect from you or about you is stored securely. We use a third party, Mailchimp, to send out our client newsletters to those who have signed up to our subscription. Mailchimp is located in the USA. Other than providing limited client contact information to Mailchimp, we will not transfer or store personal data outside UK.
In the event a transfer is made outside the UK, then this is processed with the appropriate safeguards in place as referred to in the UK GDPR or after having undertaken a risk assessment, you and we are satisfied that the data subjects of the transferred data continue to have a level of protection essentially equivalent to that under the UK protection regime, if not higher.
Unfortunately, the transmission of information via the internet is not completely secure. We do not guarantee the security of your data to our website; any transmission is at your own risk.
Sharing your personal data
We may need to disclose your personal data to some third parties in certain circumstances. This includes the following circumstances:
- Merger or Sale of our Company:In the event of an actual or potential (including as part of any relevant negotiations) merger or sale of all or substantially all of our assets to a third party, we may transfer your personal data to the potential acquirer or successor company.
- Legal Obligations:If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation including for example if we are subject to a court order to disclose your personal data, if we believe the services are being used to commit a crime or where we believe that the safety of another person is at risk.
- Enforce our Website Terms & Conditions &/or Contract for the Provision of Legal Services: In order to enforce or apply our Website Terms & Conditions or our Contract for the Provision of Legal Services, we may pass your personal data to a third party to assist us in this enforcement.
Retention of your personal data
Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If your personal data does change, please contact firstname.lastname@example.org and our records will be updated.
What rights do you have?
You have a number of rights under the data protection laws. Under certain circumstances, by law you have the right to make the following requests:
- Request access to your personal data. You have. the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:
- the purpose of the processing
- the categories of personal data
- the recipients to whom personal data has been disclosed or which will be disclosed
- the period for which the personal data will be retained
- the right to lodge a complaint with the Information Commissioner’s Office
- the source of the information if not collected direct from you, and
- the existence of any automated decision making.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it, and to have confirmation of deletion. 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).
- Object to processing of your personal data. You may object to the processing of personal data relying on the legitimate interests processing condition unless we can demonstrate compelling legitimate grounds for the processing which override your individual interests or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal information about you; for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data. This enables you to move, copy or transfer your personal data to another party where we are processing your personal data either with your consent or for the purpose of performing a contract.
Navigator has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection laws. All requests will be considered without undue delay and within one month of receipt as far as possible.
For the avoidance of doubt, we do not utilise or carry out automated decisions, which might have a legal effect on you or which might affect you significantly.
How do I exercise my rights?
To make a request to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer an electronic copy of your personal data to another party, please contact us at email@example.com.
If you have any queries regarding this policy, please contact firstname.lastname@example.org.
How do I make a complaint?
You have the right to make a complaint about anything regarding the processing, storage, retention of your personal data. We would hope to resolve any complaint internally and if you would like to lodge a complaint with us, in the first instance, please contact email@example.com.
However, you also have the right to lodge a complaint at any time to the Information Commissioner (ICO) in respect of our processing of your personal data. Further information can be found at www.ico.org.uk.