The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of Matthew Hatson. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant legislation, namely the European Union General Data Protection Regulation (GDPR) (2018).
Who we are
Our website address is: https://nexus8.co.uk.
What personal data we collect and why we collect it
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms collect data if permitted by the user. All data is stored using Mailchimp and is used expressly for the purpose for which the user gave permission.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Who we share your data with
We collect data for the following purposes:
- Opted-in period mailing list (Mailchimp)
- Enquiries on products and services (Hubspot)
- Feedback from training courses (Google Drive)
- Coaching Records (Google Drive)
- Surveys (Google Drive)
All online record keeping systems are fully GDPR compliant and we do not use any system without full and thorough certification in this area.
How long we retain your data
If you send a message, the comment and its metadata are retained indefinitely. This is so we can reply to you and maintain communication should you allow it.
For those requesting to be on our mailing list, this data is retained indefinitely or until a user requests to be unsubscribed.
For clients personal data is retained for 5 years, unless you expressly request for it to be deleted before this date.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments and messages may be checked through an automated spam detection service.
How we protect your data
Matthew Hatson as a Data Controller
In the course of its daily organisational activities, Matthew Hatson acquires, processes and stores personal data in relation to:
• Clients of Matthew Hatson
• Third party service providers engaged by Matthew Hatson
Due to the nature of the services provided by Matthew Hatson, there is regular and active exchange of personal data between Matthew Hatson and its Data Subjects. This policy provides the guidelines for this exchange of information.
What data breach procedures we have in place
he following key principles are enshrined in theEU Regulation and are fundamental to the Matthew Hatson’s Data Protection policy.
In its capacity as Data Controller, Matthew Hatson] ensures that all data shall:
1. … be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
· The identity of the Data Controller (Matthew Hatson)
· The purpose(s) for which the data is being collected
· The person(s) to whom the data may be disclosed by the Data Controller
· Any other information that is necessary so that the processing may be fair.
Matthew Hatson will meet this obligation in the following way.
· Where possible, the informed consent of the Data Subject will be sought before their data is processed;
· Where it is not possible to seek consent, Matthew Hatson will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
· Processing of the personal data will be carried out only as part of Matthew Hatson’s lawful activities, and Matthew Hatson will safeguard the rights and freedoms of the Data Subject;
· The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Matthew Hatson and operating on its behalf.
2. …. be obtained only for one or more specified, legitimate purposes.
Matthew Hatson will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Matthew Hatson holds their data, and Matthew Hatson will be able to clearly state that purpose or purposes.
3. ….. not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Matthew Hatson will be compatible with the purposes for which the data was acquired.
4. …. be kept safe and secure.
Matthew Hatson will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Matthew Hatson in its capacity as Data Controller. Access to and management of customer records is limited to those who have appropriate authorisation and password access.
5. … be kept accurate, complete and up-to-date where necessary.
Matthew Hatson will:
· ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
· conduct regular assessments in order to establish the need to keep certain Personal Data.
6. … be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
Matthew Hatson will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
7. … not be kept for longer than is necessary to satisfy the specified purpose(s).
Matthew Hatson keeps personal data for a time deemed reasonable and necessary. Once the period has elapsed, Matthew Hatson undertakes to destroy, erase or otherwise put this data beyond use.
8. … be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.
Matthew Hatson has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
What third parties we receive data from
Any third parties contracted will be given documented instructions, covering areas including confidentiality obligations, security practices, processing, storage and transfer of data and the return or destruction of the personal data at the end of the relationships.
As a Data Controller, Matthew Hatson ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation. Failure of a Data Processor to manage Matthew Hatson’s data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.
Data Breach Reporting
A breach is a loss of control, compromise, unauthorized disclosure, unauthorized acquisition, unauthorized access, or any similar term referring to situations where persons other than authorized users, for an authorized purpose, have access or potential access to personal data in usable form, whether manual or automated.
All incidents (a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed) will be reported to the Office of the Data Protection Commissioner within 72 hours. Where devices or equipment containing personal or sensitive personal data are lost or stolen, the Data Protection Commissioner is notified only where the data on such devices is not encrypted. The affected data subjects will also be informed.
Data Breach Logging
All data breaches will be recorded in an incident log as required by the Office of the Data Protection Commissioner. The log will maintain a summary record of each incident which has given rise to a risk of unauthorised disclosure, loss, destruction or alteration of personal data. The record will include a brief description of the nature of the incident and an explanation of why the Office of the Data Protection Commissioner was not informed. Such records will be provided to the Office of the Data Protection Commissioner upon request.
What automated decision making and/or profiling we do with user data
No automated decision-making or profiling is carried out using user data.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
This includes both automated and manual data.
Automated data means data held on computer, or stored with the intention that it is processed on computer.
Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, [The Company] refers to the definition issued by the Article 29 Working Party, and updated from time to time.)
Sensitive Personal Data
A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.
A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.
A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.
A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.
Relevant Filing System
Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.