Privacy

This privacy policy sets out how The worried director Limited (TWDL) uses and protects any information that you give [business name] when you use this website.

TWDL is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

TWDL may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1 July 2017.

What we collect

We may collect the following information:

• Name and job title.
• Contact information including email address
• Demographic information such as postcode, preferences and interests.
• Other information relevant to customer surveys and/or offers.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

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.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

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.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes

If you have previously agreed to us using your personal i formation for direct marketing purposes, you may change your mind at any time by writing to or emailing us at vee@navigatebr.com

Welcome to our website. If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern The worried director Limited’s relationship with you in relation to this website. If you disagree with any part of these terms and conditions, please do not use our website.

The term ‘The worried director Limited’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is 2nd Floor, 166 College Road Harrow, Middlesex HA1 1BH.

Our company registration number is 10810440. The term ‘you’ refers to the user or viewer of our website. The use of this website is subject to the following terms of use:

• • The content of the pages of this website is for your general information and use only. It is subject to change without notice.
  • Like many services, Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Browsers do not share first-party cookies across domains. To find out more about how Google treats personal information, please see The Google Privacy Policy
  • Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by the law.
  • Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
  • This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright n lice, which forms part of these terms and conditions.
  • All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
  • Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
  • From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
  • Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.
  • This website contains public sector information licensed under the Open Government Licence v3.0.

Introduction

The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Out commitment

We at TWDL are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing laws and abides by data protection principles. However, we are updating and expanding this program to meet the demands of the GDPR.

TWDL is dedicated to safeguarding the personal information in our care and in developing a data protection system that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How we, at The worried director Limited, have prepared for the GDPR

We have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR. Our preparation includes:

• • • • Information Audit – carrying out an organisation-wide information audit to identify what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
      • Policies & Procedures – implementing new data protection policies and procedures to meet the requirements of the GDPR, including:
        • Data Protection – our main policy and procedure document for data protection has been revised to meet the requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
        • Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
        • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been shared with all employees, making them aware of the reporting lines and steps to follow.
        • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
      • Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
      • Privacy Notice/Policy – we are revising our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
      • rocessor Agreements – where we use any third-party to process personal information on our behalf, we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website of an individual’s right to access personal information that TWDL processes about them and to request information about:

• • • • What personal data we hold about them.
      • The purpose of processing.
      • The categories of personal data concerned.
      • The recipients to whom the personal data has/will be disclosed.
      • How long we intend to store your personal data.
      • If we did not collect the data directly from them, information about the source.
      • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this.
      • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
      • The right to lodge a complaint or seek judicial remedy and who to contact in such instances.

Information Security and Technical and Organisational Measures

TWDL takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures.

GDPR Roles and Employees

TWDL have a designated Data Protection Lead who is responsible for promoting awareness of the GDPR across the organisation, implementing the new policies, procedures and measures.

We have engaged a data protection consultant to assess our GDPR readiness, identifying any gap areas and develop and implement our roadmap for complying with the new data protection Regulation.

TWDL understands that continuous awareness and understanding is vital to the continued compliance of the GDPR. We have implemented a training program which will provide to all employees who handle personal data and forms part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact vee@navigatebr.com