This policy sets out the Saxon Arms of Kent adherence principles and processes in relation privacy and GDPR regulatory requirements.
Saxon Arms of Kent subscribes to UK GENERAL DATA PROTECTION REGULATION 2016/679 (GDPR) legal requirements.
1. GDPR PRINCIPLES
The UK GDPR sets out seven key principles that Saxon Arms of Kent fully subscribes to:
1.1 Lawfulness, fairness and transparency
1.2 Purpose limitation
1.3 Data minimisation
1.4 Accuracy
1.5 Storage limitation
1.6 Integrity and confidentiality (security)
1.7 Accountability
2. DATA PROTECTION PRINCIPLES
Saxon Arms of Kent complies with the data protection principles set out below. When processing personal data, it ensures that:
2.1 it is processed lawfully, fairly and in a transparent manner in relation to the data subject
(‘lawfulness, fairness and transparency’)
2.2 it is collected for specified, explicit and legitimate purposes and not further processed in a
manner that is incompatible with those purposes (‘purpose limitation’)
2.3 it is adequate, relevant and limited to what is necessary in relation to the purposes for which it
is processed (‘data minimisation’)
2.4 it is accurate and, where necessary, kept up to date and that reasonable steps will be taken to
ensure that personal data that is inaccurate, is erased or rectified without delay (‘accuracy’)
2.5 it is kept in a form which permits identification of data subjects for no longer than is necessary
for the purposes for which the personal data is processed (‘storage limitation’)
2.6 it is processed in a manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental loss, destruction
or damage, using appropriate technical or organisational measures (‘integrity and
confidentiality’)
2.7 it is responsible for the management of personal data in order to demonstrate compliance with
the above principles for example:
a) adopting and implementing data protection policies;
b) maintaining documentation of our processing activities;
c) implementing appropriate security measures;
d) recording and reporting personal data breaches;
e) adhering to relevant codes of conduct and signing up to certification schemes.
3. PROCESSING PERSONAL DATA
Saxon Arms of Kent will:
3.1. Ensure that the legal basis for processing personal data is identified in advance and that all
processing complies with the law
3.2. Not do anything with a clients data that they would not expect given the content of this
policy and our privacy notice
3.3. Ensure that appropriate privacy notices are in place advising how and why their data is being
processed, and, in particular, advising Clients of their rights
3.4. Only collect and process the personal data that we need for purposes we have identified in
advance
3.5. Ensure that, as far as possible, the personal data we hold is accurate and is kept up to date.
3.6. Only hold onto personal data for as long as it is needed after which time Saxon Arms of Kent will securely erase or delete the personal data.
3.7. Ensure that appropriate security measures are in place to ensure that personal data can only
be accessed by those who need to access it and that it is held and transferred securely.
4. PERSONAL INFORMATION
“Personal Information” in this Privacy Policy, refers to information collected in order to provide the financial coaching service sessions, order Information and device information.
4. PERSONAL INFORMATION
We currently collect and process the following information:
4.1 Personal identifiers, contacts and characteristics (for example, name, address and contact
details)
4.2 Email address information
4.3 Financial information (Only what you provide)
4.4 Family information (where applicable, such as number of dependants and married status)
5. WHY WE HAVE IT
Any personal information we process is provided to us directly by you for one of the following reasons:
5.1 Contacting in event of cancellation or session change
5.2 Assessing budgetary information
5.5 Where subscribed by clients agreement, providing information and updates.
5.6 To process payments as and if required
5.8 Device Information that we collect helps us screen for potential risk and fraud (in particular
your IP address) and more generally to improve and optimise our site.
6. PERSONAL ORDER INFORMATION
Order Information we collect is to fulfil any orders placed through the site. We use this Order Information to:
6.1 Process payments
6.2 Provide invoices
6.3 Provide order confirmations
6.4 Communicate with you.
6.5 Screen payment orders for potential risk or fraud.
6.6 Provide you with information or advertising relating to our products or services (when in line
with the preferences you have shared with us).
7. PERSONAL DEVICE INFORAMTION
7.1 When you visit the site, we automatically collect certain information about your device,
including information about your web browser, IP address, time zone and some of the cookies
that are installed on your device.
7.2 Additionally, as you browse the site, we collect information about the individual web pages or
products that you view, what websites or search terms referred you to the site and information
about how you interact with the site. We refer to this automatically-collected information as
“Device Information”.
8. COLLECTING DEVICE INFORMATION USING THE FOLLOWING TECHNOLOGIES:
8.1 Cookies are data files that are placed on your device or computer and often include an
anonymous unique identifier. For more information about cookies, and how to disable
cookies, visit www.allaboutcookies.org.
8.2 Log files track actions occurring on the site and collect data including your IP address,
browser type, internet service provider, referring/exit pages and date/time stamps.
8.3 Web beacons, tags and pixels are electronic files used to record information about how you
browse the site.
8.4 Additionally, when you make a payment through the site, we collect certain information from
you including your name, billing address, shipping address, payment information (including
credit card numbers, email address, and phone number). We refer to this information as
“Order Information”.
9. BEHAVIOURAL ADVERTISING
10.1 As described above, we use your Personal Information to provide you with targeted
advertisements or marketing communications we believe may be of interest to you. 10.2 For
more information about how targeted advertising works, you can visit the Network Advertising
Initiative’s (“NAI”) educational page
at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
11. LAWFUL BASIS
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for
processing information is:
Contractual obligation:
In order for us to fulfil our contractual obligation to you the client, we need to collect all
relevant data to be able to provide you with the financial coaching service you are
paying us to help you with.
12. STORAGE OF INFORMATION
12.1 All information is securely stored. All electronic information is kept on separate external hard
drives that are securely stored in security cabinets
when not in use. All PC’s used for accessing personal data are password protected, have
specialist security software and our routers are fully encrypted.
12.2 All hard copy information is permanently stored in secure lockable cabinets as per the ICO
guidance. All keys are securely sorted in a key safe when not in use.
12.3 We keep all information provided to us by you electronically or in hard copy (Letters or
documents) for 6 months or where you exercise your data rights for erasure. We will then
dispose your information by secure deletion from separate hard drives all information is
stored on.
12.4 Hard copy information is thoroughly cross shredded and disposed of.
13. CLIENT RIGHTS
Under the terms of the General Data Protection Regulation (GDPR) you have the following rights:
13.1 To be informed if your personal data is being used - An organisation must inform you if it is
using your personal data.
13.2 To get copies of your data - You have the right to find out if an organisation is using or
storing your personal data.
13.3 Your right to get your data corrected - You can challenge the accuracy of personal data held
about you by an organisation.
13.4 To get your data deleted - You can ask an organisation to delete personal data that it holds
about you.
13.5 To limit how organisations use your data - You can limit the way an organisation uses your
personal data.
13.6 To data portability - You have the right to get your personal data from an organisation in a
way that is accessible.
13.7 To object to the use of your data - You have the right to object to the processing or use of
your personal data in some circumstances.
13.8 To make a data protection complaint - Tell an organisation if you're concerned about how
they are using your data.
14. ENQUIRIES AND PROCESSING
14.1 Saxon Arms of Kent will facilitate any request from a data subject who wishes to exercise their
right under data protection law as appropriate,
always communicating in a clear, intelligible and easily accessible form and without undue
delay. We have one month to respond to you.
14.2 For security reasons Saxon Arms of Kent may ask for proof of your identity before disclosing
information about you, or to you, via email or over the telephone.
14.3 To provide accurate complete Services Saxon Arms of Kent will need to collect information
about your personal and financial circumstances where agreed and appropriate. Saxon Arms of Kent will only use personal information to deliver the Services.
14.4 You may request a copy of the Privacy Policy at any time at enquiries@saxonarmsofkent.uk
or view it directly on our website
14.5 By using the Services and/or agreeing to these Terms, you accept Saxon Arms of Kent
practices regarding personal data and how it will be treated.
14.6 Saxon Arms of Kent will never share your data or information with any other third party except
when it is directly required to provide the Services you have requested, as outlined above, or
where you have given us explicit permission in advance to do so.
15. COMPLAINTS
If you have any concerns about our use of your personal information, you can make a complaint to us at: enquiries@saxonarmsofkent.uk
NOTE: To better understand the complete suite of GDPR rights, processes and requirements, and to gain a more in-depth understanding of GDPR regulations, we have provided a link to the Information Commissioners Office (ICO) - https://ico.org.uk
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