Data Privacy Policy
Thank you for trusting us with some information about you. We take that trust seriously and we want you to know how we use your information, and why.
1. Introduction
Who is holding your information?
Name: Emma Way Associates Ltd (EWA)
Company Registration Number: 09102239
Email : office@emmaway.uk
Third parties we share information with: See section A.7. below
Emma Way Associates Ltd (company registration number: 09102239) is the data controller and responsible for your personal data. Our contact details are as follows:
Full name of legal entity: Emma Way Associates Ltd
The Data Security and Protection lead (responsible for overseeing any questions in relation to this privacy policy) is Joy Forster, Compliance Manager. Address: 17 Uppingham Gate Uppingham LE15 9NY
Our data regulator contact details are: Information Commissioners Office. Our ICO registration number is: ZA812027
The data regulators for the UK can be found via this link: https://ico.org.uk/
2. Whose information do we collect?
We process information about:
• ‘Prospects’ – contacts working at, or connected with, potential Clients.
• ‘Clients’ – who appoint services from EWA, and ‘Client Contacts’ who are individuals employed by or contracted to Clients.
• ‘Suppliers’, ‘Associates’, ‘Referrer’- suppliers or potential suppliers of goods or services to us.
• ‘Employees’- Employees should refer to their contract of employment for data privacy information relating to their own data.
3. Our Policy
Everyone who works for EWA has some responsibility for ensuring data is collected, stored and handled appropriately. Each person that handles personal data must ensure it is handled and processed in line with this policy and data protection principles.
We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear. This policy explains how we do that – when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure. Section A is for everyone and includes information about information collected, stored and handled by EWA.
Section B is for you if you are, or work for, a prospect.
Section C is for you if you are a Client, or a Client Contact.
Section D is for you if we have information about you purely because we are providing services to a Client.
Section E is for you if you’re a supplier, referrer or associate.
SECTION A: For Everyone
A.1. Personal Data
EWA are committed to protecting your privacy and honouring your legal rights to control how your personal data is used.
EWA only collect and use personal data that is needed:
• because you have asked us to do something (for example, send you newsletters).
• so that we can reply to queries or complaints.
• to develop and manage our business relationships.
• to help grow our business and fulfil our contracts.
• to provide services to clients.
• to calculate payments to associates, supplier and referrers.
• to meet our legal obligations.
EWA try to make sure the information held is accurate and up to date and is no more than is needed.
A.2. Categories of data
The types of information that is processed will depend on the nature of the relationship between you and EWA.
EWA may process information about you that you have yourself provided or published generally including on the internet through social media or on other websites.
In all cases, EWA will have what identifying and communication information that is relevant and that EWA can sensibly obtain: that is, your name, email address, employer or business name, job title or position, contact address, social media addresses, and may also capture some of the information published by you in the public domain to the extent that it may be relevant to company interactions.
If you are, or work, for a prospect EWA will aim to obtain and process information that is relevant to building a business relationship with you and doing business together.
If you are, or work for, a customer or supplier, EWA will also keep records of interactions, the work completed for you or commissioned from you, the progress of work, and financial and accounting records.
A.3. Newsletters
EWA monitor who opens and reads our Mailchimp communications, how many times, and which links you choose to be used and read. This information is used to increase the content’s level of interest and help improve what is sent. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails. From time to time, EWA may contact individual email newsletter subscribers.
Signing onto the EWA newsletter list is by your consent and when you withdraw your consent the contact detail will be unsubscribed and stop that processing of your data.
You can unsubscribe from these at any time via the ‘unsubscribe’ button at the foot of the Mailchimp email.
Existing clients may receive emails about specific updates relating to services previously received.
EWA may contact prospects from time to time. This is normally because you have requested a call, or because we are actively trying to let you know about something you may benefit from. EWA are not a hard sell or cold-calling based organisation but prefer to build long-term relationships with satisfied clients.
A.4. Social media
EWA has an active presence on social media. If you are using social media EWA are holding and using your information in accordance with their data privacy policy.
EWA keep a record if you ‘like’ any of our posts or ‘follow’ us or contact us on social media. Your replies to EWA, messages you send EWA, and your other activity linked to EWA posts may be seen by members of EWA staff and by EWA associates.
A.5. No sale or exchange of your data
EWA do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
A.6. Data location and platforms
Like most small businesses, EWA do not have any tailor-made software – EWA use mainstream packages from client records, to email, to accounting. For more details on data storage refer to the EWA Data Security Policy.
A.7. Sharing of some of your data
EWA have an outsourced support team for our own business which may include Web Designers, IT support, Sales and Marketing and Accounting. They have limited access to your data, where the service they provide means they need it. For example, if IT support wants to check the functionality of a laptop or back up, they may need temporary access to information that may include something about you or, if you are invoiced, our accountant needs to process the information in the invoice.
EWA use software with company accounts to access data they need. EWA do not permit copying or sharing unless the process requires and actively monitor for any potential breaches.
Your information is held in the strictest confidence. EWA associates, employees and suppliers are all contracted to strict confidentiality clauses and have received Data Security training.
EWA restrict who can export or download data that is held to a limited number of authorised individuals.
A.8. Retention period
Subject to your rights as a data subject and applicable data protection law, EWA may process and store your personal data for a period of up to 7 years as long as the data subject is actively receiving and acting upon contact from EWA. In any event, EWA will not hold on to data for longer than is needed for the purposes for which it was gathered.
If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.
For more details on data storage refer to the EWA Data Retention Policy.
A.9. Subject access requests
All individuals who are the subject of personal data held by EWA are entitled to:
• Ask the purposes of our processing.
• Ask for the categories of personal data concerned.
• Ask who are the recipients that we are disclosing your personal data to.
• Ask for a copy of your personal data.
• Ask how long we will store your personal data.
• Ask for your rights to request rectification, erasure or restriction or to object to such processing.
• Ask for the right to lodge a complaint with the Information Commissioner’s Office.
• Ask for information about the source of data, when not obtained directly from you.
• Ask whether we use automated decision making.
• Ask about the safeguards we provide if we transfer your personal data to a third party or organisation.
If an individual contacts the company requesting this information, this is called a Subject Access Request. All subject access requests should be made to the following email address: office@emmaway.uk. The Compliance Manager will review the request and aim to provide the relevant data within 14 days, although the law stipulates a time period of 1 month to respond. The Compliance Manager will always verify the identity of anyone making a subject access request before handing over the required information.
A.10. What are your rights
You have the right to know what information EWA are collecting on you, and to amend it if it is inaccurate.
If you feel EWA have information they should not be keeping, or it is out of date or otherwise wrong, please contact office@emmaway.uk and appropriate action will be taken.
You have a “right to be forgotten” – but that does have some legal limits to it. If you want us to remove information about you please contact office@emmaway.uk. If you have been a client, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and insurer requirements.
A.11. EWA Legal basis for processing your data
Apart from that, the information held is based on needing the information to run the business and provide associated products and services – either so the contract with you can be performed, or because there is a legitimate business interest in processing your data.
In a few situations EWA are processing personal data because we are under a legal obligation to do so. This principally relates to business, accounting and tax records.
SECTION B: Prospects
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us. In addition to the above:
• If you sign up to a newsletter list, you will be sent what you asked for.
• If we email you individually using our own email system or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.
• We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
SECTION C: Clients
Once you instruct us, we will collect information from you at the point of instruction. In addition to details in Section A and Section B we collect data so we can provide what we have contracted to, invoice you and keep proper records of our business relationship.
We process your data to support the delivery of the services you have agreed to. We keep records of the services provided to you, and information you give us, so we can support you when needed and advise you of any additional services you may need.
• EWA will use your data in accordance with the client agreement and client consent form completed between the ‘Client’ and EWA.
• EWA will only obtain special category data i.e. sensitive and/or criminal offence data where necessary for reasons of substantial public interest, such as to comply with anti-money laundering and anti-terrorism financing regulations.
• EWA may use electronic verification providers to check data provided, to ensure we comply with anti-money laundering and anti-terrorism financing regulations.
C.1. Third party data
As well as your own personal data, we understand that you may need to provide us with personal data relating to your employees, your workers, or third parties – depending on the services we are providing to you. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
C.2. Financial details
If you pay us by BACS or direct transfer, we know only what the bank tells us, which is usually the name of the person who paid us and how much and the reference number.
SECTION D: Third party information
We will act in accordance with your statutory rights, subject to the exclusions and exemptions that may apply.
When we are processing data about you on behalf of a client, we are operating under the banner of our client’s data privacy policy if applicable. We will refer any enquiry from you to them, but we will support that by providing relevant information from our client for passing to you.
When we are processing data about you because of a direct connection between you and our business we are acting as a ‘data controller’ (and operating under this policy).
SECTION E: Suppliers, referrers and associates
If you become a supplier or associate we keep a copy of the contract between us and/or the client, and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertake for EWA and our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is all needed to manage our client relationships and our suppliers.
If you are a referrer, we remind you that referrals you make to us, or EWA make to you, may only be made with the knowledge and consent of the person being referred.
4. Complaints If you have any concerns about our use of your personal information you can request a copy of the EWA Compliment and Complaints policy or make a complaint to us at:
Emma Way Associates Ltd
17 Uppingham Gate
Uppingham
LE15 9NY
T | 01664 840730
E | complaints@emmaway.uk
You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
https://ico.org.uk/
5. Review
EWA’s Data Privacy Policy and all other policies are reviewed annually.
1. Introduction
Who is holding your information?
Name: Emma Way Associates Ltd (EWA)
Company Registration Number: 09102239
Email : office@emmaway.uk
Third parties we share information with: See section A.7. below
Emma Way Associates Ltd (company registration number: 09102239) is the data controller and responsible for your personal data. Our contact details are as follows:
Full name of legal entity: Emma Way Associates Ltd
The Data Security and Protection lead (responsible for overseeing any questions in relation to this privacy policy) is Joy Forster, Compliance Manager. Address: 17 Uppingham Gate Uppingham LE15 9NY
Our data regulator contact details are: Information Commissioners Office. Our ICO registration number is: ZA812027
The data regulators for the UK can be found via this link: https://ico.org.uk/
2. Whose information do we collect?
We process information about:
• ‘Prospects’ – contacts working at, or connected with, potential Clients.
• ‘Clients’ – who appoint services from EWA, and ‘Client Contacts’ who are individuals employed by or contracted to Clients.
• ‘Suppliers’, ‘Associates’, ‘Referrer’- suppliers or potential suppliers of goods or services to us.
• ‘Employees’- Employees should refer to their contract of employment for data privacy information relating to their own data.
3. Our Policy
Everyone who works for EWA has some responsibility for ensuring data is collected, stored and handled appropriately. Each person that handles personal data must ensure it is handled and processed in line with this policy and data protection principles.
We promise respectful treatment of the personal information of everyone we have contact with. We want it to be simple and clear. This policy explains how we do that – when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure. Section A is for everyone and includes information about information collected, stored and handled by EWA.
Section B is for you if you are, or work for, a prospect.
Section C is for you if you are a Client, or a Client Contact.
Section D is for you if we have information about you purely because we are providing services to a Client.
Section E is for you if you’re a supplier, referrer or associate.
SECTION A: For Everyone
A.1. Personal Data
EWA are committed to protecting your privacy and honouring your legal rights to control how your personal data is used.
EWA only collect and use personal data that is needed:
• because you have asked us to do something (for example, send you newsletters).
• so that we can reply to queries or complaints.
• to develop and manage our business relationships.
• to help grow our business and fulfil our contracts.
• to provide services to clients.
• to calculate payments to associates, supplier and referrers.
• to meet our legal obligations.
EWA try to make sure the information held is accurate and up to date and is no more than is needed.
A.2. Categories of data
The types of information that is processed will depend on the nature of the relationship between you and EWA.
EWA may process information about you that you have yourself provided or published generally including on the internet through social media or on other websites.
In all cases, EWA will have what identifying and communication information that is relevant and that EWA can sensibly obtain: that is, your name, email address, employer or business name, job title or position, contact address, social media addresses, and may also capture some of the information published by you in the public domain to the extent that it may be relevant to company interactions.
If you are, or work, for a prospect EWA will aim to obtain and process information that is relevant to building a business relationship with you and doing business together.
If you are, or work for, a customer or supplier, EWA will also keep records of interactions, the work completed for you or commissioned from you, the progress of work, and financial and accounting records.
A.3. Newsletters
EWA monitor who opens and reads our Mailchimp communications, how many times, and which links you choose to be used and read. This information is used to increase the content’s level of interest and help improve what is sent. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails. From time to time, EWA may contact individual email newsletter subscribers.
Signing onto the EWA newsletter list is by your consent and when you withdraw your consent the contact detail will be unsubscribed and stop that processing of your data.
You can unsubscribe from these at any time via the ‘unsubscribe’ button at the foot of the Mailchimp email.
Existing clients may receive emails about specific updates relating to services previously received.
EWA may contact prospects from time to time. This is normally because you have requested a call, or because we are actively trying to let you know about something you may benefit from. EWA are not a hard sell or cold-calling based organisation but prefer to build long-term relationships with satisfied clients.
A.4. Social media
EWA has an active presence on social media. If you are using social media EWA are holding and using your information in accordance with their data privacy policy.
EWA keep a record if you ‘like’ any of our posts or ‘follow’ us or contact us on social media. Your replies to EWA, messages you send EWA, and your other activity linked to EWA posts may be seen by members of EWA staff and by EWA associates.
A.5. No sale or exchange of your data
EWA do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
A.6. Data location and platforms
Like most small businesses, EWA do not have any tailor-made software – EWA use mainstream packages from client records, to email, to accounting. For more details on data storage refer to the EWA Data Security Policy.
A.7. Sharing of some of your data
EWA have an outsourced support team for our own business which may include Web Designers, IT support, Sales and Marketing and Accounting. They have limited access to your data, where the service they provide means they need it. For example, if IT support wants to check the functionality of a laptop or back up, they may need temporary access to information that may include something about you or, if you are invoiced, our accountant needs to process the information in the invoice.
EWA use software with company accounts to access data they need. EWA do not permit copying or sharing unless the process requires and actively monitor for any potential breaches.
Your information is held in the strictest confidence. EWA associates, employees and suppliers are all contracted to strict confidentiality clauses and have received Data Security training.
EWA restrict who can export or download data that is held to a limited number of authorised individuals.
A.8. Retention period
Subject to your rights as a data subject and applicable data protection law, EWA may process and store your personal data for a period of up to 7 years as long as the data subject is actively receiving and acting upon contact from EWA. In any event, EWA will not hold on to data for longer than is needed for the purposes for which it was gathered.
If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.
For more details on data storage refer to the EWA Data Retention Policy.
A.9. Subject access requests
All individuals who are the subject of personal data held by EWA are entitled to:
• Ask the purposes of our processing.
• Ask for the categories of personal data concerned.
• Ask who are the recipients that we are disclosing your personal data to.
• Ask for a copy of your personal data.
• Ask how long we will store your personal data.
• Ask for your rights to request rectification, erasure or restriction or to object to such processing.
• Ask for the right to lodge a complaint with the Information Commissioner’s Office.
• Ask for information about the source of data, when not obtained directly from you.
• Ask whether we use automated decision making.
• Ask about the safeguards we provide if we transfer your personal data to a third party or organisation.
If an individual contacts the company requesting this information, this is called a Subject Access Request. All subject access requests should be made to the following email address: office@emmaway.uk. The Compliance Manager will review the request and aim to provide the relevant data within 14 days, although the law stipulates a time period of 1 month to respond. The Compliance Manager will always verify the identity of anyone making a subject access request before handing over the required information.
A.10. What are your rights
You have the right to know what information EWA are collecting on you, and to amend it if it is inaccurate.
If you feel EWA have information they should not be keeping, or it is out of date or otherwise wrong, please contact office@emmaway.uk and appropriate action will be taken.
You have a “right to be forgotten” – but that does have some legal limits to it. If you want us to remove information about you please contact office@emmaway.uk. If you have been a client, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and insurer requirements.
A.11. EWA Legal basis for processing your data
Apart from that, the information held is based on needing the information to run the business and provide associated products and services – either so the contract with you can be performed, or because there is a legitimate business interest in processing your data.
In a few situations EWA are processing personal data because we are under a legal obligation to do so. This principally relates to business, accounting and tax records.
SECTION B: Prospects
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us. In addition to the above:
• If you sign up to a newsletter list, you will be sent what you asked for.
• If we email you individually using our own email system or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored.
• We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
SECTION C: Clients
Once you instruct us, we will collect information from you at the point of instruction. In addition to details in Section A and Section B we collect data so we can provide what we have contracted to, invoice you and keep proper records of our business relationship.
We process your data to support the delivery of the services you have agreed to. We keep records of the services provided to you, and information you give us, so we can support you when needed and advise you of any additional services you may need.
• EWA will use your data in accordance with the client agreement and client consent form completed between the ‘Client’ and EWA.
• EWA will only obtain special category data i.e. sensitive and/or criminal offence data where necessary for reasons of substantial public interest, such as to comply with anti-money laundering and anti-terrorism financing regulations.
• EWA may use electronic verification providers to check data provided, to ensure we comply with anti-money laundering and anti-terrorism financing regulations.
C.1. Third party data
As well as your own personal data, we understand that you may need to provide us with personal data relating to your employees, your workers, or third parties – depending on the services we are providing to you. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
C.2. Financial details
If you pay us by BACS or direct transfer, we know only what the bank tells us, which is usually the name of the person who paid us and how much and the reference number.
SECTION D: Third party information
We will act in accordance with your statutory rights, subject to the exclusions and exemptions that may apply.
When we are processing data about you on behalf of a client, we are operating under the banner of our client’s data privacy policy if applicable. We will refer any enquiry from you to them, but we will support that by providing relevant information from our client for passing to you.
When we are processing data about you because of a direct connection between you and our business we are acting as a ‘data controller’ (and operating under this policy).
SECTION E: Suppliers, referrers and associates
If you become a supplier or associate we keep a copy of the contract between us and/or the client, and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertake for EWA and our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is all needed to manage our client relationships and our suppliers.
If you are a referrer, we remind you that referrals you make to us, or EWA make to you, may only be made with the knowledge and consent of the person being referred.
4. Complaints If you have any concerns about our use of your personal information you can request a copy of the EWA Compliment and Complaints policy or make a complaint to us at:
Emma Way Associates Ltd
17 Uppingham Gate
Uppingham
LE15 9NY
T | 01664 840730
E | complaints@emmaway.uk
You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
https://ico.org.uk/
5. Review
EWA’s Data Privacy Policy and all other policies are reviewed annually.