Privacy Policy

Introduction

This privacy notice provides you with details of how we, Redstone Psychology and PBS Limited, collect and process your personal data and (for corporate clients) how we collect and process personal data relating to your employees, people you support or educate and customers. This may be relevant whilst we are providing services to you or any organisation you represent, when we meet you, communicate with you via e-mail or hard copy correspondence, when you engage with us via social media, when you attend (or register to attend) one of our events or through your use of our website, including any data you may provide through our website or when you sign up to our newsletter or webinars.

We have appointed a Data Protection Officer who is in charge of privacy related matters. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

Full name of legal entity: Redstone Psychology and PBS Limited

Name or title of Data Protection Officer: Kate Strutt

Email address: [email protected]

Postal address: c/o Workplace, 4th Floor, Broadhurst House, 56, Oxford Street, Manchester. M1 6EU

Telephone number: 0161 864 2160

Obtaining personal data and updates from you

Where we are required to collect personal data by law, or where we need personal data from you in order to provide services under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the services. If you don’t provide us with the requested data, we may have to cancel a service you have asked us to provide, but if we do, we will notify you at the time.

It is very important that the information we hold about you or (for corporate clients) your company, people you support or educate, and your customers is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

The data protection principles

We adhere to the principles relating to processing of personal data set out in the General Data Protection Regulation (GDPR) which require Personal Data to be:

Used lawfully, fairly and in a transparent way.
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.
Accurate and up to date.
Kept as long as necessary for the purposes we have told you about.
Kept securely.

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.

2 What data do we collect about you, for what purpose and on what grounds we process it

What is personal data?

“Personal data” means any information capable of identifying an individual. It does not include anonymised data. We collect information from you when you fall into one (or more) of the following categories:

“Clients” means focus persons or any other individual natural person for whom we are providing services in their personal capacity.
“Representatives” means individual natural persons who have instructed us to provide services either on behalf of another person (e.g. a minor or individual lacking mental capacity) or to a company, partnership, trust, estate, agency, department, other forms of corporate entities or any other group or organisation (whether incorporated or unincorporated) whom they represent.
“Subscribers” means any individual natural person who has signed up to one of our newsletters or bulletins, has signed up for any online courses, has attended (or registered to attend) any of our events (whether those events be put on by us or in conjunction with a third party), follows us on social media or has made an enquiry us, whether via our website, or otherwise, either in their capacity as a potential Client or a potential Representative.

Please note you may fall into one or more of the above categories and as a result we may hold your personal information in a number of different capacities.

Purposes for which we will use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:

we need to perform the contract we are about to enter into or have entered into with you (whether that be in your capacity as a Client or where you are a Representative on behalf of our ultimate client); or
it is necessary for our “legitimate interests” (see below) or those of a third party and your interests and fundamental rights do not override those interests; or
we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact details set out at paragraph 1 of this Privacy Notice.

Where in this Privacy Notice we refer to our “Legitimate Interest” we mean our interest in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the contact details set out at paragraph 1 of this Privacy Notice at any time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose (if necessary). For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent, where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Types of Personal Data

Purpose / Lawful basis for processing

“Customer Data” that includes:

Name (including any maiden name), title, gender, job title;
email address, home address, telephone numbers;
your employer’s details and business address (if you are representing a company);
date of birth;
employment information (either about your work or if you are representing a company, information about that company and other employees).

Purpose:

We use this information to enable us to provide the services to you, to manage our relationship during the contract and to manage any disputes that may occur in respect of the contract and to contact you with marketing communications (see below) to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Lawful basis:

(a) Performance of a contract with you (or the organisation you represent if you are a Representative)

(b) Necessary to comply with a legal obligation

(c) Necessary to protect the vital interests of the person(s) you represent where you are a Representative of a minor or an individual lacking mental or physical capacity, or where we have been asked to provide services relating to that person by their parent, public body or independent organisation.

(d) Necessary for our legitimate interests (e.g. to ensure effective administration and management of your relationship, to manage any disputes and take legal or other professional advice and to tell you about the various services we can offer.)

“Customer Data” that includes:

Payment information such as your credit or debit card details.
Information about the services you have purchased.
Communication / Social Media data (includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us).

Purpose:

We use this information to:

enable us to provide the services to you;
to take payments, to ensure effective administration and management of your contract and your relationship with us.
to ensure effective administration and management of your contract and our relationship with you, and to form a view on what we think you may want or need, or what may be of interest to you to decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing

Lawful basis:

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests (e.g. to recover debts due to us).

(d) Necessary to protect the vital interests of the person(s) you represent where you are a Representative of a minor or an individual lacking mental or physical capacity, or where we have been asked to provide services relating to that person by their parent, public body or independent organisation.

(e) Necessary for our legitimate interests (e.g. to understand how our customers use our services, to carry out research and analysis on what services our customers want or how they would like us to improve our services, to tell you about the various services we can offer, or to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims).

“User Data” that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.

Purpose:

We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business.

Lawful basis:

Our legitimate interests which in this case are to enable us to properly administer our website and our business.

“Technical Data” that includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.

Purpose:

We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.

Lawful basis:

Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

“Combined Data”: We use combinations of the data listed above (with the exception of Sensitive/Special Category data).

Purpose:

To deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you.

Lawful basis:

Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

3 How we collect personal data via our websites or from publicly available sources

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this see:

http://redstonepbs.co.uk/wp-content/uploads/2016/02/RedstoneCookiePolicy.pdf

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4 Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We will not share your personal data or that of your customers with any third party for their own marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, the provision of services to you or the people you support.

5 Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 2 above, for example, we can share your personal data other organisations who help us to provide our services or who are providing service in collaboration with us, or who perform technical operations (such as data storage and hosting on our behalf). We may share personal data that relates to you (including where you are acting as a Representative of a minor or an individual lacking mental or physical capacity), a focus person, or a service user, or your family members (if applicable) with the following:

Third party organisations and individuals who we may have to work in conjunction with to provide our services. This may include:
1. Care providers (including family members);
2. Social workers and family support service providers;
3. Educational institutions and providers of education services;
4. Healthcare providers.
Service providers acting as processors based inside and outside of the EEA who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
The Health and Care Professionals Council for the purposes of regulatory compliance and complaints.
Our insurers for matters relating to our professional indemnity insurance in relation to the services we provide.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third party service providers who require access to your data in the course of providing their services to us. This would include organisations providing the following services: public relations and marketing, IT support, practice/case/document management systems, printing and reprographics support, event hosting services, e-mail marketing management systems (e.g. Active Campaign), survey, polling and market research/insights services (e.g. survey monkey),
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6 International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following adequate safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us using the contact details set out at paragraph 1 of this Privacy Policy at any time if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7 Data security

We have put in place security measures to prevent your personal data and that of your customers from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data and that of your customers only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8 Data retention

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers for six years after they stop being customers.

The law also requires us to retain health records for a specific period of time and we adhere to the current guidance on this.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9 Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details set out at paragraph 1 of this Privacy Policy at any time.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you wish to exercise any of the rights set out above, please email us at [email protected].

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10 Third party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies on our website, please see

http://redstonepbs.co.uk/wpcontent/uploads/2016/02/RedstoneCookiePolicy.pdf