Privacy Notice for Customers
What is the purpose of this document?
This privacy notice outlines how we, Cambridge Occupational Analysts Ltd registered company number 02049351 (“COA”), collect, store and use the personal data that you provide to us through your use of our websites such as when you sign up to our newsletter and/or when you purchase our programmes, books, request information or register for events (whether through our website, or by phone or email).
We are committed to safeguarding your personal information. Whenever you provide personal information to us, we are legally obliged to use it in accordance with all laws concerning the protection of personal information (we refer to these laws collectively in this privacy notice as the “data protection laws”).
This privacy notice applies to customers that purchase programmes or books from us and/or use our websites.
It is important that you read this notice, together with any other privacy notice or policy we may provide on specific occasions when we are collecting or processing personal information.
What information will we collect about you?
Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, store, and use the following categories of personal information about you:
Identity and contact details such as your name, title, billing address, delivery address email address and telephone number.
Financial data such as your bank account and payment card details.
Transaction data including details about payments to and from you and other details of products you have purchased from us.
Technical and usage data about how you use our website and about your equipment, browsing actions and patterns.
Marketing and communications data including your preferences on receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How will we collect and use your personal information?
We typically collect your personal information directly from you through your use of our website or if you attend an event we hold.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal information when meeting us at our events or by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you purchase our products, subscribe to our newsletter or other publications, request marketing to be sent to you or give us some feedback.
Automated technologies or interactions As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also use analytics providers such as Google to collect technical data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Lawful basis for processing including basis of legitimate interest
To process and deliver your order and to otherwise manage our relationship with you.
Performance of a contract with you.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud etc.)
To deliver relevant website content to you and use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to keep our website updated and relevant, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Necessary for our legitimate interests (to develop our products/services and grow our business)
Where we need to collect your personal data for the purposes set out above (for example, to enter into or fulfil a contract with you), if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the products that you wish to purchase or the newsletter that you wish to receive) or we may not be able to otherwise provide our services to you (for example, responding to a request or query that you submit to us).
We may use your identity, contact, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods from us and, in each case, you have not opted out of receiving that marketing.
You can opt out of receiving marketing messages from us at any time.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
How will we share and disclose your personal information?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another lawful basis for doing so.
We may need to share your personal information with the following parties for the relevant purposes set out above:
Our payment providers (such as Stripe, PayPal and WorldPay).
Our service providers supplying IT and system administration services and other technical IT services including data analytics.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Where the third parties we use are data controllers in their own right (for example, the payment processors we use) then they will be also subject to data protection laws.
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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from us using the details in the “Contacting us” section below.
We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction Data) for six years after they cease being customers for legal and tax purposes.
In some circumstances you can ask us to delete your data: see section below for further information.
Please note that we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your data protection rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information. This may include the following rights:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. 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 exercised your right to object to processing (see below).
Object to processing of your personal information This right applies where we are relying on our legitimate interests (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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party (known as the “right to data portability”).
Right to withdraw consent. In any circumstances where we have relied on your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. This will not affect the lawfulness of any processing carried out before you withdrew your consent.
If you wish to exercise any of the rights set out above, please contact us using the details in our “Contacting us” section 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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Data Protection Authority
You have the right to make a complaint at any time to the UK supervisory authority for data protection issues. This is the Information Commissioner's Office (ICO) whose details can be accessed via the ICO website at https://ico.org.uk/global/contact-us/
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do get in touch using the details in our “Contacting us” section below.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please let us know using the “Contacting us” details below.
Our details are as follows:
Cambridge Occupational Analysts Ltd
Joseph King House
Abbey Farm Commercial Park
Horsham St Faith
Tel: +44 (0)1362 688395
COA Privacy Notice for Customers May 2018 v0.2