PRIVACY POLICY

1. Data protection principles

We are committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;

2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

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2. General provisions

1. This policy applies to all personal data processed by us.

2. The Responsible Person shall take responsibility for our ongoing compliance with this policy.

3. This policy shall be reviewed at least annually.

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3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, we shall maintain a Register of information that we hold.

2. The Register of information shall be reviewed at least annually.

3. Individuals have the right to access their personal data and any such requests made to us shall be dealt with in a timely manner.

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4. Lawful purposes

1. All data processed by us must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).

2. We shall note the appropriate lawful basis in the Register of information.

3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in our systems. 

5. Data minimisation

1. We shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

2. We will only collect and store data which is needed for the use of our ongoing interests and commitments.

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6. Accuracy

1. We shall take reasonable steps to ensure personal data is accurate.

2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

3. All data will be reviewed on an annual basis to make sure all information held by us is current and up to date.

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7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, we shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

2. The archiving policy shall consider what data should/must be retained, for how long, and why.

3. If at anytime you wish for any data we hold on you to be removed this can be requested by emailing info@evansandson.net

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8. Security

1. We shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 

2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

3. When personal data is deleted this should be done safely such that the data is irrecoverable.

4. Appropriate back-up and disaster recovery solutions shall be in place.

 

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO in accordance to ICO guidelines.(more information on the ICO website).

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10. Cookies

Our website uses cookies to enhance the user experience and use of our site.

Cookies are small files placed on your device when you visit our Website. We use cookies to recognise you and your preferences, improve the performance of our Website and to create statistical data.

Cookies generally fall into one of the following categories:

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1. strictly necessary cookies which are cookies that are required to allow you to use a website and its features;

2. performance cookies which recognise and collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;

3. functionality cookies which allow the website to remember you and provide a more personalised service to you;

4. targeting or advertising cookies which are used to deliver adverts relevant to you;

 

Our Website uses the following types of cookies: strictly necessary cookies, performance cookies, functionality cookies and those, where you have provided explicit consent, targeting or advertising cookies. Some of our cookies may remain on your device between your browsing sessions.

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You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of our Website.