GDPR: DATA PRIVACY NOTICE FOR CLIENTS, CONSULTANTS AND SUPPLIERS
Philip Rickinson Associates Ltd (PRA Architects) is committed to protecting and respecting your privacy.
This policy (together with any other information referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully in order to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”), which becomes effective from 25th May 2018.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to a person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include for example, sexual orientation or ethnic origin
Processing – means any action which is undertaken on personal data including by automated means, i.e. collection or making available such.
Third party – means a natural or legal individual, public authority, agency or body other than the data subject, controller, processor and persons who have the direct authority of the controller or processor, to process personal data.
2. Who are we?
Philip Rickinson Associates Ltd (t/a PRA Architects) is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: PRA Architects, 55 The Tannery, Lawrence Street, York YO10 3WH Tel No. 01904 653772. Email: firstname.lastname@example.org
For all data matters and for the purposes of this document the data processor is Carole Rickinson email email@example.com
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
Maintaining contact and communication with you during the course of a potential, new or existing project.
Maintaining our own records and accounts.
To appraise you of news, events or activities.
To purchase supplies and services from you.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
• Personal data may include your name, address, email address, phone number, financial data for payment purposes such as VAT registration and bank details.
We have obtained your personal data from you, your employees or from publicly available data from websites.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
For the operation of a contract or to take steps For the legitimate purposes of operating our business
To enter into a contract with the data subject
Processing necessary for the purposes of Contact details of clients and the design team members
the legitimate interests of the data controller for project contacts and for marketing purposes
or a third party, except where such interests
are overridden by the interests or fundamental Data used for the purposes of purchasing supplies or
rights or freedoms of the data subject services for the legitimate operation of the business.
b) Special categories of personal data (article 9 of GDPR)
Data falling within these categories is not relevant to our operations.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with directors, HR administrative and finance staff where necessary, and contact details with members of the design team for project contacts.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary, but may be for a period of 7 or 12 years beyond the end of the contract with you. Examples include: in case of accountancy (6 years from the end of the last company financial year they relate to) or any legal claims/complaints in regard to contracts under seal (12 years).
8. Providing us with your personal data
You are under no statutory or contractual obligation or requirement to provide us with your personal data, however, failure to do so may result in: The reduction or prevention of communication with you during the contract; delay or prevention of payment for goods and services.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you
• The right to request that we rectify any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), (where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not usually transfer personal data outside the EEA, unless a specific project, client or supplier is based outside of the EEA, in which case project team contact details may be shared for communication purposes only.
11. Automated Decision Making
We do not use any form of automated decision making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, we will contact you directly.
14. How to make a complaint
The first point of contact if you have a complaint is Carole Rickinson on 01904 653772 email firstname.lastname@example.org
If we are unable to resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.