THIS IS A TEMPLATE POLICY. YOU SHOULD ENSURE IT IS REVIEWED BY YOUR SOLICITORS TO CONFIRM IT IS SUITABLE FOR YOUR EXACT NEEDS BEFORE PUBLISHING.
OUR PRIVACY AND COOKIES POLICY
[Organisation] is committed to respecting your privacy and the privacy of every [visitor to our web site/person completing this form/signing up to this service]. The information we collect about you will be used to fulfil the required services and enable us to improve how, as an organisation, we deal with you.
Should you have a question about the data we store, our contact details are:
Address Line 1
Address Line 2
The information that we collect about you will only be used lawfully (in accordance with the Data Protection Act 1998 and the General Data Protection Regulation 2018). All data is retained exclusively within the United Kingdom, or transferred only to ‘third countries’ where ‘adequacy of protection’ or specific certification as defined by The GDPR has been confirmed.
This information will not be disclosed to anyone outside [Organisation] or its associated companies, partners, and other companies with which [Organisation] has arranged services for your benefit.
We expect the information we hold to be accurate and up to date. You have the right as an individual to find out what information we hold about you and make changes if necessary; you also have the right, assuming we are not obligated by law to refuse, to ask us to stop using the information. To have your information removed or rectified, please contact [firstname.lastname@example.org].
The type of information that we will collect on you, and you voluntarily provide to us on this [website/form/service] includes:
* Your name
* Telephone number(s)
* Email address
* Survey responses
* IP address
* [etc etc]
We may, in further dealings with you, extend this information to include your address, purchases, services used, and subscriptions, records of conversations and agreements and payment transactions [etc etc].
[Assuming they are not, delete if they are]You are under no statutory or contractual requirement or obligation to provide us with your personal information; however we require at least the information above in order for us to deal with you as a [prospect or customer/member/service user] in an efficient and effective manner.
The legal basis for processing your data is based on your [specific consent/performance of a contract/compliance with a legal obligation/your vital interest/our legitimate interest] that we will have [requested/stated] at the point the information was initially provided, therefore we will not store, process or transfer your data outside the parties detailed above unless we have an appropriate lawful reason to do so. Unless we are precluded from doing so by law, you have the right to remove your consent at any time [via the unsubscribe link included on all emails we send, or] by contacting us and requesting that processing of your details be restricted or deleted.
Unless otherwise required by law, your data will be stored for a period of [2 years] after [our last contact with you/some other identifiable action or period], at which point it will be deleted.
PROTECTION OF PERSONAL INFORMATION
[Organisation] takes precautions, including administrative, technical, and physical measures, to safeguard your Data against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.
[Organisation] uses industry-standard efforts to safeguard the confidentiality of Data, including encryption, firewalls and SSL (Secure Sockets Layer). We have implemented reasonable administrative, technical, and physical security controls to protect against the loss, misuse, or alteration of your Data.
[Delete Cookies and Analytics sections if policy not website related]
If you have a concern about how we handle your data, or you would like to lodge a complaint, you may do so by contacting The Information Commissioners Office.
We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
The list below describes the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that by using our website you agree we can place these types of cookies on your device. If you are not happy, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)
FIRST PARTY COOKIES
These are cookies that are set by this website directly.
• Login: A login cookie is used to preserve your personal login preferences as set on the login screen.
You can find out more about Google’s position on privacy as regards its analytics service here.
• Banner advertising: These cookies allow us to know whether or not you’ve seen an advert and how long it is since you’ve seen it.
• PPC: These cookies use Flashtalking and Google Analytics to track our PPC campaigns by dropping cookies onto users’ browsers.
More info on Flashtalking and Google Analytics can be found here:
THIRD PARTY COOKIES
These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks.
Cookies are currently set by:
In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website.
You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
Some emails we send we track, at an individual level, whether the user has opened and clicked on the email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every email we send.
BLOCKING & DELETING COOKIES
Most browsers allow you to refuse to accept cookies. For example:
• Internet Explorer – to refuse all cookies click “Tools”, “Internet Options”, “Privacy”, and select “Block all cookies” using the sliding selector
• Firefox – to block all cookies click “Tools”, “Options”, and un-check “Accept cookies from sites” in the “Privacy” box or select “Clear private data” if you want to delete all cookies.
• Chrome – click on the Chrome menu in the toolbar, click on “settings”, click on “advanced settings”, choose “Privacy” section, then click on ” Content settings” button and choose either block or delete as appropriate.
Blocking or deleting all cookies will, however, have a negative impact upon the usability of many websites.