How we use your information
This privacy notice tells you what to expect when we collect personal information. It applies to information we collect about:
- Visitors to our websites
- Complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry
- People who use our services, eg who contact us through the website or who subscribe to newsletter services that we may implement from time to time
- People who notify under the Data Protection Act
- Job applicants and our current and former employees
Visitors to our websites
When someone visits this website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting this website. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
In order to comply with the EU Cookie Directive we need to tell you what cookies we use and why we use them. This only applies to cookies that are not intrinsic to the functioning of the website. So, for example, if this were an e-commerce site which used cookies to hold your shopping cart information, we would not be obliged to notify you about those cookies.
Here is a summary of the cookies we use and why…
Cookie Family : Google Analytics
Cookie Name(s) : _utma _utmb _utmc _utmz
Cookie Use : These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where vistors have come to the site from and the pages they visited. Click here for an overview of privacy at Google or opt out of being tracked by Google Analytics across all websites.
Cookie Family : WordPress
Cookie Name : wp-settings-time
Cookie Use : This website runs on the WordPress platform. This is a very widely used content management system that helps website owners to run robust websites and easily manage the content on those websites. WordPress is used in roughly 16% of all new websites being built. WordPress sets several cookies, for example, to track logged-in users, and also to track blog commenters. This is perfectly normal, and operation of the website would be very difficult without them.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
We may from time to time embed videos from YouTube using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube’s embedding videos information page.
People who call our helpline
When you call us we may collect Calling Line Identification (CLI) information. We use this information to help improve efficiency and effectiveness.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may from time to time compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for four years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not identify any complainants unless the details have already been made public.
People who use our services
We may offer various services to the public. For example, we send out publications and distribute an electronic newsletter. Where we use a third party to deal with publication requests they are only allowed to use the information to send out the publications.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
People who ‘notify’ under the Data Protection Act 1998
Many businesses are required by law to ‘notify’ certain specified information to the Information Commissioner. This may contain personal information, for example where the business is a sole trader. Where we compile this information into a register, it is required by law to make it publicly available. We put technical measures in place to prevent the bulk down-load of the electronic version of the register. However, as the register is publicly available, we cannot give any guarantees as to how the information contained on the register will be used by those accessing it.
When businesses fill in their notification forms, they are asked to provide the contact details of a relevant member of staff. We will use this for our own purposes, for example where we have a query about a notification, but will not put it on the public register.
When we request information as part of the notification process, we make it clear where the provision of information is required by law and where it is voluntary.
Complaints or queries
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Access to personal information
We try to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
give you a description of it;
tell you why we are holding it;
tell you who it could be disclosed to; and
let you have a copy of the information in an intelligible form.
To make a request to us for any personal information we may hold you need to put the request in writing addressing it to our Internal Compliance Team, or writing to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Internal Compliance Team.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 16th June 2018.
How to contact us
Internal Compliance Department, 26 route des Terres Noires, 33590 Talais FRANCE