GDPR - Privacy Notice

Thrive2Distinction Ltd is professional consultancy business based in the United Kingdom (EU) and was established in 2018. As an organisation, we provide GDPR Practitioner work, Technical Consultancy, Business Process Consultancy, Troubleshooting and Training Services.

Data Protection Officer

Under the regulation, Thrive2Distinction Ltd does not require a Data Protection Officer however, our senior data controller and GDPR practitioner can be contacted on:

Email: datacontroller@thrive2distinction.co.uk
Tel: 01702 480281

The data we will process on your behalf include:

  • Name

  • Company name

  • Company address

  • Telephone number

  • Email address

  • IP address (for Support reasons)

  • Usernames and passwords (for Support reasons)

  • Invoice address

  • Account details

  • Direct debit details

Our Legal Basis for Processing your Personal Data:

We will process your data securely under the following legal basis:

  • We require a name, address, telephone number, email address for secure identification and correspondence during your consultancy agreement.

  • We require your invoice and/or direct debit details in order for us to charge the agreed price for the support and services you receive.

Legitimate interests pursued by us or third parties we use, are as follows:

  • Your contact details may be shared with some third parties who provide services on our behalf. These details are not shared furthermore except merely held for reasons relating to the service being provide to you.

 

Special Categories of Personal Data:

  • We do not store any 'special' personal data such as driving license, passport, or national insurance number.

  • We may ask to 'view' an item of 'special' personal data if being asked to hand over sensitive data and we are required to identify an authorised recipient in order to prevent a data breach

Disclosure:

Thrive2Distinction Ltd will not pass on your data to third parties without first obtaining consent.

Retention Policy:

Thrive2Distinction Ltd will process personal data for a maximum of 7 years to coincide with HMRC and accounting records. The exception being I.T. related configuration data which, in the event of a client moving to an alternative support provider will be secure deleted for security reasons.

 

Your Rights as a Data Subject:

As a data subject, you will have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.

  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.

  • Right to object – you have the right to object to certain types of processing such as direct marketing.

  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

  • Right to judicial review: in the event that Thrive2Distinction Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

 

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. In line with Subject Access Request Procedure (GDPR DOC 2.2) and Subject Access Request Form (GDPR REC 4.2). Thrive2Distinction Ltd provide a data subject with a Data Subject Access Form (SAR).

Complaints:

In the event that you wish to make a complaint about how your personal data is being processed by Thrive2Distinction Ltd (or its third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority which is the ICO (www.ico.org.uk).

 

You can report a concern directly with the ICO, if RES Info-Tech fails to handle your complaint in an appropriate manner: https://ico.org.uk/concerns/

 

Please send any initial complaints to: datacontroller@thrive2distinction.co.uk  or contact directly on Tel: 01702480281

 

Specific Online Privacy Statement

Personal data:

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information online:

This privacy notice tells you how we, Thrive2Distinction Ltd, will collect and use your personal data for from our secure contact form which refers to this policy for consent that you allow us collect personal data, for example: name, Email and contact telephone. You data will be processed for contact purposes only. 

Why does Thrive2Distinction Ltd need to collect and store personal data?

In order for us to provide you any level of service we need to collect personal data for correspondence purposes . In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Thrive2Distinction Ltd would contact you for additional consent, unless you have formerly ticked the consent option on our contact form.

Will Thrive2Distinction Ltd share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Thrive2Distinction Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Thrive2Distinction Ltd’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Thrive2Distinction Ltd use the personal data it collects about me?

Thrive2Distinction Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Thrive2Distinction Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

 

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

Thrive2Distinction Ltd at your request, can confirm what information we hold about you and how it is processed. If Thrive2Distinction Ltd does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.

  • Contact details of the data protection officer, where applicable.

  • The purpose of the processing as well as the legal basis for processing.

  • If the processing is based on the legitimate interests of Thrive2Distinction Ltd or a third party, information about those interests.

  • The categories of personal data collected, stored and processed.

  • Recipient(s) or categories of recipients that the data is/will be disclosed to.

  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely.

 

The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

  • How long the data will be stored.

  • Details of your rights to correct, erase, restrict or object to such processing.

  • Information about your right to withdraw consent at any time.

  • How to lodge a complaint with the supervisory authority.

  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

  • The source of personal data if it wasn’t collected directly from you.

  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

 

What forms of ID will I need to provide in order to access this?

Thrive2Distinction Ltd accepts any of the following forms of ID when information on your personal data is requested:

  • Passport

  • Driving licence

  • Another form for ID which leaves no doubt of the data owner