Transferring information outside the EEA
We do not routinely transfer the personal information we collect about you outside of the European Economic Area (EEA). However, in the event that we did, to ensure that your personal information does receive an adequate level of protection we will put in place appropriate protective measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
Appropriate specific protective measure(s) include, for example, model contractual clauses and security assessments. If you require further information about these appropriate protective measures, you can request it from email@example.com.
10. How we protect your data
We have put in place measures to protect the security of your information. Details of these measures are available upon request from firstname.lastname@example.org
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure
We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from email@example.com.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11. How long we retain your data for
We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from dpo@Stepchange.org.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.
12. What your rights are: rights of access, rectification, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. This request would need to be in writing.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no legal reason for us continuing to process it. 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). This request would need to be in writing.
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the restriction of processing of your personal information. 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 a copy of your personal information for transfer to another party.
If you want to request a copy of the personal information we hold about you, or request erasure of your personal information, please contact firstname.lastname@example.org in writing detailing your request.
If you want to review, verify, correct your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using your usual method or email email@example.com
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. You will be informed of this in writing, where this is the case.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your explicit consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact us or use the appropriate unsubscribe links available. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so in law.
13. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Find out on their website how to report a concern or call the ICO helpline on 0303 123 1113.
14. Changes to this notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates that would affect your rights or how we process your personal data. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact firstname.lastname@example.org
Version 1.0 - updated 25/05/2018