Please read the following
before using this site
This Privacy Notice sets out the basis on which Create Britain Partnership Ltd trading as CreateBritain® will process personal information provided to us, this information is also referred to as ‘personal data’. CreateBritain® is referred to throughout as “we”, “us”, “our” and “ours”.
We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.
We are a directory and promotion business and we are also an employer. Our core business activity is Directory and Promotion Services, we assist individuals, groups and organisations in both finding information and promoting their services. We also recruit staff to work for us to provide our services. For the purposes of this Privacy Notice, our commercial activities and services are referred to as ‘Directory and Promotion Services’, and our actual or potential customers are referred to as ‘Clients’.
The person responsible for data protection matters within our organisation is Richard Woods, Director and can be contacted at richard@createbritain.com
If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us, Please refer to Section ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.
Section 1:
This section applies to individuals wishing to use or using our Directory and Promotion Services:
The personal data we collect or receive includes the following:
- Name
- Address, Town or Postcode
- Email and other contact details
- Current/previous employers and positions held
- Information relating to skills, experience, sector disciplines and specialisms
- Links to publicly available Professional and Social Media pages
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
- You
- Industry directories
- News articles and promotional material
- Professional and Social Media channels
- The public domain
- Notes following a conversation or meeting
- Other websites
Where you are a Client and we have obtained your personal data from a third party such as Social Media, it is our policy to advise you of this when we first communicate with you.
How we will use your personal data:
The processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Posting your details, other than your contact email (unless this is your public email), on our online public directory
- Notifying you of CreateBritain® services or features that we feel could be of interest to you
- Notifying you of events, news or features relevant to your sector disciplines or specialisms
- Contacting and encouraging you to complete your profile
- Advising you of potential and relevant roles or opportunities
- Collating market or sector specific information and providing the same to our Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to directories or promotion
- To market our Directory and Promotion Services
- Retaining a record of our dealings
- For the purposes of backing up information on our computer systems
Why we process your personal data:
1. Entering into and performing a contract with you:
In order to provide our Directory or Promotion Services we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations. For example, to promote you as a Premium entry, payment details will be required.
2. Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Directory and Promotion Services, which necessitate the processing of personal data. These include the Privacy and Electronic Communications Regulations, which amongst other things requires us to:
- Tell individuals, groups or organisations
- Provide an option to opt out
We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.
3. Our legitimate interests (carrying on the commercial activity of Directory and Promotion Services):
In providing our Directory and Promotion Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
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Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- establishing compliance with contractual obligations
- addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- protecting our reputation
- maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- evaluating quality and compliance including compliance with this Privacy Notice
- determining staff training and system requirements
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Using your personal data to:
- assess relevance and contact you regarding potential opportunities and/or our services
- collate market information or trends including providing analysis to potential or actual Clients
- personalise your experience and our offering, whether via our website or otherwise
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
4. Consent to our processing of your data:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you wish to be included within the directory against certain criteria including: categories; disciplines; specialisms or locations. In other cases you may have provided your written or verbal consent to the use of your data for a specific reason.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals, groups and organisations for the purposes of creating a directory. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and specialist directories, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from organisations and colleagues, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Directory or Promotion Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see ‘Your rights’.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration for directory or promotion services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you. This will be for one or more of the following reasons:
- You have explicitly consented to the processing
- For the purpose of identifying your creative disciplines, specialisms and location for accurate inclusion within the directry
- Where processing is necessary for the purpose of obligations or rights under Privacy and Electronic Communications Regulations or law
- To maintain records of our dealings to address any later dispute, including but not limited tothe establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
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A coalition partner where registration within a badged community is part of a collaboration. Coalition partners may include:
- regional authority (including third party evaluators)
- professional body
- college or university
- membership group
- Parties who process data on our behalf which may include:
- IT support
- storage service providers including cloud
- Legal and professional advisers
- Insurers
Automated decisions
We may use software to review the personal data recorded on our directory. The software may be used to determine relevance for promotional activity.
Section 2:
This section applies where you are an individual working for a third party with whom we have dealings. For example, a client or an Technology or Data Storage company.
We may collect your personal data in the course of our dealings and this may include the following:
- Your contact information, which may include your full name, job role, contact telephone number and email
- Your marketing preferences
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
- You, including where you have provided us with your contact details or other information for the purposes of using our Directory or Promotion Services
- Staff or other representatives of the organisation you represent
- Marketing databases
- Social media
- The public domain
- Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings
- Notes following a conversation, with you or others, or meetings you attend
How we will use your personal data:
We will process your personal data in the context of our dealings with the third party and as part of our Direction and Promotion Services. Processing may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Using the data to communicate with you
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to directories or promotion
- Collating market or sector specific information and providing the same to our clients
- Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers
- Retaining records of our dealings with you and any organisation whom you represent
- Establishing quality, training and compliance with our obligations and best practice
Why we process your personal data:
1. Compliance with legal obligations (regulatory and statutory obligations)
We must comply with a number of statutory provisions when providing our Directory and Promotion Recruitment Services, which necessitate the processing of personal data. These include the Privacy and Electronic Communications Regulations, which amongst other things requires us to advise people of their inclusion within the directory and give them the chance to opt out.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities such as HMRC.
2. Our legitimate interests (carrying on the commercial activity of Directory and Promotion Services):
In providing our Directory and Promotion Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
- Using your personal data:
- to contact you regarding our Directory and Promotion Services
- to collate market information or trends including providing analysis to potential or actual Clients
- as otherwise necessary to provide our Directory and Promotion Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers
- to personalise your experience and our offering, whether via our website or otherwise
-
Retaining records of our dealings and transactions and where applicable, use such records for the purposes of:
- establishing compliance with contractual obligations with Clients or suppliers
- addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- protecting our reputation
- maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- evaluating quality and compliance including compliance with this Privacy Notice
- determining staff training and system requirements
For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.
3. Consent
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose.
You may withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information for the purposes of populating the directory. This may include obtaining personal data from sources including LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from organisations and colleagues or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Directory and Promotion Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section ‘Your rights’.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Directory and Promotion Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Directory and Promotion Services. This will be for one or more of the following reasons:
- You have explicitly consented to the processing
- Where processing is necessary for the purpose of obligations or rights under the Privacy and Electronic Communications Regulations or law
- To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
Who we share personal data with:
We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
- Parties who process data on our behalf, which may include
- IT support
- storage service providers including cloud providers
- Legal and professional advisers
- Insurers
Section 3:
This section applies to all personal data
If you do not wish to provide us with necessary data
There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Directory or Promotion Services. If you do not wish to provide us with information we request then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Directory or Promotion Service, and in some cases may result in a breach of the contract we have with you or a third party you represent.
Group companies & transfer
Although this Privacy Notice applies to us your data may be accessible to, and shared with other organisations within our group for any of the purposes set out within this Privacy Notice, or where we have shared administration systems and staff.
In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.
Data Security and Confidentiality
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
Cookies
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.
We use cookies to distinguish you from other users. This helps provide you with a good browsing experience and also allows us to improve our service. By continuing to browse the site, you are agreeing to our use of cookies.
We use cookies that are Necessary for the site operation. They include, for example, cookies that enable you to log into secure areas of the site.
We use Analytical cookies to recognise and count the number of visitors and to see how visitors move around the site to help us improve the way it works.
We use Recognition cookies to identify you when you return. This enables us to personalise our content for you and remember your preferences.
We also use Targeting cookies to record the pages you have visited and the links you have followed. This will allow us to make the site and the advertising displayed on it more relevant to you. We may also share this information with third parties for this purpose. Third parties including advertising networks and analysis services may also use cookies, over which we have no control.
You can block cookies on your browser, however, if you block all cookies, you may not be able to navigate parts of our site.
Retaining your data
In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where we are subject to a legal obligation which applies for a longer period.
If however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section ‘Your Rights’ below.
Changes to this Privacy Notice
This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same.
Section 4:
Your rights
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
- Request a copy of the personal data that we hold
- Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
- Request that we restrict processing of your data in certain circumstances
- Request that data is erased where the continued use of that data cannot be justified
- Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
- Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
- Request that inaccurate or incomplete data is rectified
- Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
- Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact Richard Woods, Director, richard@createbritain.com
Complaints
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to Richard Woods, Director, richard@createbritain.com. This does not affect your right to make a complaint to the Information Commissioner’s Office.
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