Inspired Usability Privacy Policy
1. Document Information
QMS-18-0005-D_D
2. Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to any services we provide in the European Economic Area (EEA).
3. Key Terms
Inspired Usability Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). This just means that we determine the purposes and ways in which we process personal data.
As a data controller, we take your privacy and our responsibilities very seriously. This is our privacy notice. It provides you with details the type of personal data we hold, the way in which we collect it and how we process it.
Full name of legal entity: Inspired Usability Limited
Postal address: 41c Abbey Road, Knaresborough, United Kingdom, HG5 8HY
Email address: dataprotection@inspiredusability.com
Miranda Newbery has been appointed as our Data Protection Officer and is therefore responsible for all privacy related matters. If you have any questions about how we process your personal data or anything set out in this privacy notice, please contact the Data Protection Officer whose details are as follows:
Miranda Newbery
Inspired Usability Limited
41c Abbey Road
Knaresborough
HG5 8HY
Tel: +447855943098
Email: dataprotection@inspiredusability.com
| Personal data | Any information relating to an identified or identifiable individual |
| We, us, our | Inspired Usability Limited |
| Our data protection officer | Miranda Newbery – dataprotection@inspiredusability.com |
| Special Category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation |
| Data subject | The individual who the personal data relates to |
4. Personal Data We Collect About You
Any information that can identify you as an individual is known as ‘Personal Data’. This does not include any anonymised data.
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
• your name and contact information, including email address and telephone number and company details;
• information to check and verify your identity;
• your financial information for processing any payments to you;
• Information about how you use our website, IT, communication and other systems;
• Video and audio recordings.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
5. How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email. However, we may also collect information:
• from publicly accessible sources, eg Companies House or HM Land Registry;
• directly from a third party, eg:
– sanctions screening providers;
– credit reference agencies;
– customer due diligence providers;
• from a third party with your consent,
• from cookies on our website—for more information on our use of cookies, please see our cookie policy below
• via our IT systems, eg through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.
6. How and why do we use your personal data?
Under data protection law, we can only use your personal data if we have a proper reason, eg:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Providing services | To perform our contract with you or a third party and to take steps at your or a third party’s request before entering into a contract |
| Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us |
| Conducting checks to verify identity
Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service at the best price |
| Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations |
| Preventing unauthorised access and modifications to systems | Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations |
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Updating and enhancing customer records | Depending on the circumstances: —to perform our contracts with you or third parties or to take steps before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch with our customers |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests, ie to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests, ie to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts | Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
7. How and why we use your personal data – in more detail
More details about how we use your personal data and why are set out in the table below.
Addressing and sending communications to you or our customers as required by lawProcessing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))Depending on the circumstances this may include your name, address and contact information, including email address and telephone number and company details
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR and EU GDPR | Relevant categories of personal data |
|---|---|---|---|
| Communications with you or our customers not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you or our customers as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018; —the EU GDPR |
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | —your name, address and contact information, including email address and telephone number and company details; |
| Communications with you or our customers not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you or our customers as required by law | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | Depending on the circumstances this may include your name, address and contact information, including email address and telephone number and company details |
| Communications with you or our customers not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Addressing and sending communications to you or our customers about changes to our terms or policies or changes to the products or other important notices | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | —your name, address and contact information, including email address and telephone number and company details |
8. How and why we use your personal data – Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
• personal data revealing racial or ethnic origin;
• genetic data;
• biometric data (where used for identification purposes);
• data concerning health; and
• data concerning a person’s sexual orientation.
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.
9. How and why we use your personal data – sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
10. Marketing communications
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us at dataprotection@inspiredusability.com at any time.
11. Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver our services to you, eg payment service providers and other companies;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• credit reference agencies;
• our insurers and brokers;
• our bank;
• screening providers
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
• our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
12. Who we share your personal data with – further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
13. Where your personal data is held
Personal data may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
14. How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data.
Following the end of the of any relevant retention period, we will delete or anonymise your personal data.
15. Transferring your personal data out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
• our customers or service providers located outside the UK; and
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
16. Transferring your personal data out of the UK and EEA – further information
If you would like further information about data transferred outside the UK/EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).
17. Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.
18. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
19. How to complain
Sometimes, we might get something wrong. If we do, we want to put it right. We would really appreciate it if you would contact us first to try and resolve the issue if you ever have any cause to be unhappy with any aspect of the way in which we collect and use your data. Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
• the Information Commissioner in the UK
• a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint/ or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
20. How to contact us
Individuals in the UK: You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our data Protection Officer’s contact details:
Miranda Newbery
Inspired Usability Limited
41c Abbey Road, Knaresborough, HG5 8HY, UK
dataprotection@inspiredusability.com
Telephone: +447855943098
Inspired Usability – Cookies
1. Introduction
1.1 Our website uses analytics cookies to analyse site traffic and improve the user experience
1.2 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website
1.3 No cookies will be set until your approval is given
2. About cookies
2.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server
2.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed
2.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies
2.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website
3. Our cookies
3.1 We use persistent cookies on our website
3.2 If you allow cookies to be stored for this site, a cookie called ‘pva-cookie-consent’ will be set to store your preference. In addition, Google Analytics cookies will also be set as described below
4. Analytics cookies
4.1 We use Google Analytics to analyse the use of our website
4.2 Our analytics service provider generates statistical and other information about website use by means of cookies
4.3 The analytics cookies used by our website have the following names: pva_ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv
4.4 The information generated relating to our website is used to create reports about the use of our website
4.5 Our analytics service provider’s privacy policy is available at: http://www.google.com/policies/privacy/
5. Third party cookies
5.1 Our website does not use third party cookies
6. Blocking cookies
6.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”
(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”
(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading
6.2 Blocking all cookies will have a negative impact upon the usability of many websites
7. Deleting cookies
7.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11)
(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”
(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”
7.2 Deleting cookies will have a negative impact on the usability of many websites
8. Cookie preferences
8.1 You can manage your preferences relating to the use of cookies on our website by changing the setting at the top of this page. For reference, the URL is https://inspiredusability.com/privacy-policy/
