Privacy & GDPR Notice - Governance360This is the Privacy & GDPR notice of the service provided by Board Secure Limited, trading as Governance360
This Notice sets out the obligations of Board Secure Limited (“The Company”), a company registered in England under number 11363367 and whose trading names include Governance360, regarding data protection and the rights of our users (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
Board Secure Limited takes your privacy very seriously and knows that you care how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
We respect and value the privacy of everyone who visits this website, www.governance360.co.uk and our platform website at www.boardsecure.co.uk (“Our Site”) and who use Our App and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of Our Privacy Notice is deemed to occur upon your first use of our site and You will be required to read and accept this Privacy Notice when signing up for an Account/App. If you do not accept and agree with this Privacy Notice, you must stop using Our Site and Our App immediately.
1. Definitions and Interpretation
In this Notice, the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed;
in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller;
means any and all people who we hold the personal data for. This could mean subscribers of Board Secure (account holders), affiliates of Board Secure and/or people who have electively given us their data and permission to market to them. In these circumstances, we are the Data Controller. Or it could mean clients of our subscribers, a user of Board Secure (usually the staff of the account holder) or people who have been referred to us by an affiliate. In these circumstances, we are the Data Processor, where the subscriber or the affiliate is the Data Controller;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
means Board Secure Ltd, trading as Governance360, a limited company registered in England under company number 11363367, whose registered address is Innovation Birmingham Campus, iCentrum, Holt Street, Birmingham, B7 4BB.
“Your Board’s personal data”
means any and all data that relates to your Board and its members which you choose to enter into your app as a customer of Board Secure. This data is considered to be your data and is managed, stored, retrieved and deleted in different ways as outlined in this Privacy Notice; and
2. Information about Us
This Notice sets out the obligations of Board Secure Limited a limited company registered in England under number 11363367, whose registered address is Innovation Birmingham Campus, iCentrum, Holt Street, Birmingham, B7 4BB.
VAT number: 317342813
ICO registration number: ZA509974
Email address: [email protected]
Postal Address: Innovation Birmingham Campus, iCentrum, Holt Street, Birmingham, B7 4BB
3. What does this Notice cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data and your client’s personal data.
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you or your clients that enables you or them to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 6, below.
5. What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 13 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 13 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Part 6 explains more about how we use your personal data, including automated decision-making and
- For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 13.
- Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
- If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Personal Data do you collect?
Your Personal Data
We may collect some or all of the following personal data (this may vary according to your relationship with us:
- Email address;
- Telephone number;
- Business name;
- Job title;
Your Board’s Personal Data
If you are a client of Board Secure, you will be adding your Board’s personal data to the App for the effective use of our service. This will vary dependent on the use of the App for your work, although we have designed our service to ensure that no sensitive data, as defined by the legislation, is kept or personally identifiable and we ask you to ensure that the platform is not used to store sensitive data as defined under the GDPR.
7. How do you use my Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products and services to you. Your personal details are required in order for our to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email, text message and post that you have opted-in to (you may unsubscribe or opt-out at any time by choosing ‘unsubscribe’ in our correspondence or by contacting us).
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We do not make use of any automated systems for carrying out certain kinds of decision-making and profiling.
8. How long will you keep my personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Personal data for marketing purposes prior to you signing up to become a client – this will be retained until you fail to engage with our content for a period of 6 months or until you opt-out of our communications.
- Personal data for marketing purposes whilst you’re a client – this will be retained for the duration of you being a client so we can best support you and provide you with information about relevant products and services, which we also provide and which we fell you will also benefit from.
- Personal data for marketing purposes after you were a client – this will be retained until you fail to engage with our content for a period of 6 months or until you opt-out of our communications.
- Your Board’s personal data – this will be retained until you delete it from your app on a Board by Board basis, request that we remove all of your Board’s data from your app or until you cancel your app/subscription with us, at which point it will be deleted in its entirety following a suitable period of time, typically one month after cessation of payment.
9. How and Where Do You Store or Transfer My Personal Data?
We outline the stringent security measures we take to store your personal data securely in our Security Measures section on the website at www.governance360.co.uk.
Whilst we seek to minimise the transfer of data outside of the UK, we may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR including:
- Ensuring that the companies we use to store your data are absolutely critical to the providing of our service. These include Google Firebase in particular.
- Ensuring that the method of passing data to them complies with the securest methods appropriate to the passing and nature of that data, for example our use of encryption throughout the whole of the App as outlined in our Security Measures section.
10. Do you share my personal data?
We will not share any of your personal data or your client’s data with any third parties for any purposes except for one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held).
You may also request to have your Board’s personal data exported from your app, this will then typically be provided as a file (usually CSV). We can do this for you upon the request of the account holder. To do this, please just contact us (see part 13.)
This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13. To make this as easy as possible for you, we may ask you to complete a Subject Access Request Form, which is available from us on request.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. How can I have my data erased?
If you wish for your personal data to be erased from our various systems, please contact us (See Part 13) and we will follow our strict procedures to ensure that all of your data has been removed from our systems.
If you are a customer of Board Secure and you want your Board’s personal data to be removed from our system, then you have the ability to do this yourself in the main by deleting your Board’s papers and history form our platform yourself.
If you wish for ALL of your Board’s data to be removed in bulk, then please contact us and we can do this for you (see part 13.)
13. How do I contact you?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Clive Bawden):
Email address: [email protected]
Postal Address: Innovation Birmingham Campus, iCentrum, Holt Street, Birmingham, B7 4BB.
15. What if there is a data breach?
We work to the highest levels of security, which can be found in our Security Measures page. However, in the unlikely event of a data breach, then:
- If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the responsible member of our team will ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
- In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
- Data breach notifications shall include the following information:
- The categories and approximate number of data subjects concerned;
- The categories and approximate number of personal data records concerned;
- The name and contact details of the Company’s responsible officer (or other contact point where more information can be obtained);
- The likely consequences of the breach;
- Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
16. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available here.
17. BoardSecure users only
If you are a subscriber of Board Secure, then we will also be storing your Board’s data. You therefore may have an obligation under GPDR to inform your clients about where we store their data, how it can be retrieved and how it can be erased. If so, here is sample statement you could use. Please note that we cannot verify the legal validity of this statement and you should have it verified by your own advisers before sharing it.