Nicola Askham Limited Privacy Policy

Our privacy policy is in line with the Data Protection Act 2018, the retained EU law version of General Data Protection Regulation ((EU) 2016/679) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) ("Data Protection Legislation"). At Nicola Askham Limited, we respect the privacy of visitors to our website (https://www.nicolaaskham.com/) and that of those companies and individuals that we work with and to whom we provide services.

Your Privacy

We take our duty to process your personal information in accordance with Data Protection Legislation very seriously. This policy explains how we collect, manage, use, process and store the personal information of visitors to our website and those that we provide services to, what we do with it and what controls you have over your personal information.

We may change this document from time to time to reflect what we do with your information. Please check back frequently to see if we have made any changes to this Privacy Policy. This Privacy Policy has at the end of it the date on which it was last updated.

Please see the sections below for more details on how we collect, process and store your personal information and how we use it:

1. Who are we?

2. What personal information do we collect and how do we use it?

3. Basis upon which we will process your personal information

4. Sharing your information

5. Retaining your information

6. Our cookie policy

7. What are your rights?

8. How to contact us

9. How to contact the Information Commissioner's Office.

In this Privacy Policy references to "we" or "us" are to Nicola Askham Limited, which is a registered company in England and Wales with registration number 07557425. Our registered office address is 1 Hillcrest Road, Orpington, Kent, England, BR6 9AN.

We have appointed a data privacy manager ("DPM"). If you have any questions about this Privacy Notice or our data protection practices, please contact the DPM using the contact details set out in Section 8 below.

You have the right to make a complaint at any time to the Information Commissioner’s Office ("ICO") - see Section 9 below.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

In this Privacy Policy "personal data" or "personal information" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (this is referred to as "anonymous data").

The information that we collect from you will depend on whether you are a visitor to our website and ask us to provide you with information and updates (such as newsletters) or have asked us to provide you with services (such as training (whether in person or via online courses), coaching or consultancy).

Nicola Askham Limited is what’s known as the ‘controller’ of the personal information you provide to us. We will usually collect basic personal information about you like your name, postal address, telephone number, email address and your payment details, if you are purchasing any services or courses from us. However, from time to time we may need further or more detailed information from you, such as to enter into or comply with the terms of a contract entered into with you.

The sorts of data we may collect from you, depending on whether you are a visitor to our website or are purchasing services from us is:

• Identity Data including first name, last name, company name and job title;

• Contact Data including address/billing address, email address and telephone numbers;

• Financial Data including bank account and payment card details;

• Transaction Data including details about payments to and from you, and other details of courses, digital content and/or services you have purchased from us;

• Marketing and Communications Data including your preferences in receiving marketing communications from us; and

• Profile Data including your username and password, purchases, orders and bookings made by you, your interests, preferences, feedback and survey responses.

• We may also store information from cookies placed on our website, such as your IP address and location.

Where we are collecting information from you. we will be very clear with you that we wish to collect such information, our reason for collecting that information, and we will only do so with your consent.

WHY WE NEED YOUR PERSONAL INFORMATION

We collect your personal information in connection with specific activities, such as emailing electronic newsletters, event bookings, managing course registrations, entering into contracts with you to provide services or courses, performing our contractual obligations with you and obtaining feedback and information from you.

The personal information we collect from you is either needed to fulfil a request from you, to provide further information or follow up on an enquiry, to allow us to enter into and/or perform our contractual obligations or to enable us to provide you with a more personalised service. You don't have to disclose any of this information to browse our website. However, where we need to collect personal data to follow up an enquiry from our site, by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to follow up on your enquiry or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service or course access you have with us, but we will notify you if this is the case at the time.

Our marketing

Sometimes, with your consent, we will collect and use your personal information to provide you with information about our work or our activities that you have requested or are expecting.

On other occasions, we may process personal information when we need to do this to fulfil a contract (for example, if you have purchased training courses) or where we are required to do this by law or other regulations.

Nicola Askham Limited processes your information when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with content on Data Governance, information on our upcoming events, services, newsletter requests, feedback, and other activities. Where you have purchased services or a course from us we will use your personal information to contact you and provide information about the course and to process your payments.

How we obtain your details

Generally, you directly provide Nicola Askham Limited with the personal data we collect.

We collect and process data when:

• you provide it to us directly (for example to register interest in any of our digital content, downloads and services or marketing materials through our website or register (or are registered by your employer) for a course or training we provide,;

• you enter into a contract with us for us to provide services (for example, coaching, training or consultancy);

• you use or view our website via your browser’s cookies; and/or

• when you have given it to a third party and have provided permission to pass your information on to us.

We will also hold information about the personal information you have provided so that we can respect your preferences for being contacted by us.

Children

If you are under 16, please ensure you obtain your parent/guardian's consent before sending any personal information to any website or Nicola Askham Limited.

Please note that we will not knowingly market to or accept orders for goods or services from persons aged under 18 years.

As a parent or guardian we encourage you to be aware of the activities in which your children are participating, both offline and online. If your children voluntarily disclose information, this may encourage unsolicited messages. We suggest that you discourage your child from providing any information without your consent.

Anything else?

Wherever possible we ensure that all the personal information we process is processed within the UK or EEA or other countries which have been approved as providing an adequate level of protection for personal information. If personal information is transferred outside these areas, additional controls such as Standard Contractual Clauses will be used to protect the rights of the individual. This will be done in accordance with guidance issued by the Information Commissioner’s Office. All transfers will be effected in accordance with Data Protection Legislation.

If you would like to change the way you hear from us or no longer wish to receive direct marketing communications from then use the contact form on our 'Contact' page or get in touch using our contact details in Section 8 below.

Under the Data Protection Legislation, we must always have a lawful basis for using personal data.

Most commonly, we will use your personal data in the following circumstances:

1. Where we need to use your personal data for Performance of a Contract we are about to enter into or have entered into with you.

2. Where it is necessary because we or a third party have a Legitimate Interest in doing so and your interests and fundamental rights do not override those interests.

3. Where we need to Comply with a Legal Obligation.

4. Where we have obtained your prior Consent.

For these purposes, the following phrases have the following meanings:

• Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or take steps at your request before entering into such a contract.

• Legitimate Interest means the interests of our business in conducting and managing our business to enable us to give you the best service and content suited to your interests and requirements. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

• Consent means that you have given your consent by agreeing that we can use your information or send you information by taking some action to affirm this, such as opting in or ticking a box to confirm you agree.

Generally, we do not rely on Consent as a legal basis for processing your personal data except where you sign up to our newsletter or register for events, although we will get your Consent before sending third party direct marketing communications to you via email or text message.

How we may use your personal information

Direct Marketing: We will send email marketing which furthers the aims and objectives of Nicola Askham Limited. We will also make sure our email marketing is relevant for you and, where you have indicated what matters you are interested in, tailored to your interests.

Event registration: In order for us to register you for an event, payment has to be taken and contact information collected, such as name, credit card number and telephone number.

Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.

Personalisation: Where the use of the information enables us to personalise, enhance or otherwise improve our communications for the benefit of our customers.

Analytics: To use your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

Due Diligence: We need to undertake due diligence on potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.

Contracts: Processing your information where it is necessary for the performance of a contract to which you are a party or take steps at your request before entering into such a contract.

We will also hold information about you so that we can respect your preferences for being contacted by us.

Our legitimate business interests do not automatically override your interests – we will never use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law).

Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using our contact form on the 'Contact' page or contacting us using the details in Section 8 below.

We do not share your information with any other organisations or individuals unless we are when obliged to by law, for purposes of national security, taxation and criminal investigations and in the following instances:

• If you have agreed that we may do so.

• When we use other companies to provide services on our behalf, e.g. sending emails, customer analysis, assessment, when using auditors/advisors or processing credit/debit card payments.

• If we merge with another organisation to form a new entity, information may be transferred to the new entity.

• We may disclose aggregate statistics about our site visitors, supporters, customers and sales to describe our services and operations to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information.

• If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register.

And, we will never sell or rent your personal information to other organisations.

We have put 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 or where you have given your consent to this. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal data for no longer than necessary to fulfil the purposes we collected it for; this timescale is dependent on the nature of your relationship with us. We have provided some examples of the time for which we will keep your personal information in this Section but you can contact us for more information.

If you decide that you do not want further information about our services, courses and events or request that we have no further contact with you, we will keep some basic information in order to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information.

If you make a purchase from us or engage us to provide services or training courses to you, we will keep the purchase information for a period of seven years for accounting and legal purposes.

If you sign up for our newsletter we will retain your details for as long as you wish to receive the emails and will delete your details within one week of you unsubscribing.

Our website uses cookies to distinguish you from other users of our website.  This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.  For detailed information on the cookies we use and the purposes for which we use them please see the SquareSpace Cookie policy.

You can set your browser not to accept cookies or go to https://allaboutcookies.org to find out how to remove cookies from your browser.  However, in a few cases, this may result in some features of our website not functioning properly.

Every user is entitled to the following:

• The right to access

You have the right to request from us for copies of your personal information, this is commonly known as a “data subject access request”.  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

•  The right to rectification

You have the right to request that we correct any information you believe is inaccurate.  You also have the right to request that we complete information that you believe is incomplete, though we may need to verify the accuracy of the new data you provide to us.

•  The right to erasure

You have the right to request us to erase your personal information (sometimes known as "the right to be forgotten").  This enables you to ask us to delete or remove personal information  where there is no good 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal information  to comply with local law.  Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•  The right to restrict processing

You have the right to request us to restrict the processing of your personal information, under certain conditions.  This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information  but we need to verify whether we have overriding legitimate grounds to use it.

•  The right to object to processing

You have the right to object to our 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, as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•  The right to data portability

You have the right to request that we transfer what we have collected to another organisation, or directly to you, under certain conditions.  Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

•  The right to withdraw consent

You have the right to withdraw consent where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us at the address given in Section 8 below.

 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 is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal information  is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

 If you make a request, we have one month to respond to your request.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

If you would like to know more about your rights under the Date Protection Legislation, you can find out more at the Information Commissioners Office website.

 Remember, you can change the way you hear from us or withdraw your permission for us to process your personal information at any time by using the form on our 'Contact' page or see our contact details in Section 8 below.

If you wish to talk through anything in our privacy policy, find out more about your rights or obtain a copy of the information we hold about you, please contact us (details are at the bottom of this page), we will be happy to help.

If you wish to raise a complaint on how we have handled your personal information, you can contact our DPM  nicola@nicolaaskham.com who will investigate the matter.  If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain to the Information Commissioner’s Office ("ICO").

If you wish to talk to us about anything in the policy or the information we hold about you please contact us:

By telephone: +44 7854 983700

By email: nicola@nicolaaskham.com

By post: 1 Hillcrest Road, Orpington, Kent BR6 9AN, UK

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address.

 If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office:

Address: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

For further ways to contact the Information Commissioner’s Office, go to: https://ico.org.uk/global/privacy-notice/how-you-can-contact-us/

Last Updated: 6 September 2022