Privacy Notice & Data Process Statement
This is the Privacy Notice and Data Processing Statement for ‘JWB Consulting’ (‘us’ or ‘we). By using our website and/or engaging with our services we respect your privacy and are committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
For those organisations that wish to engage our services, we include at Appendix 1 of this Notice a copy of our Data Processing Statement which explains how we will handle any personal data provided to us by you. The Data Processing Statement is for information purposes only and is not intended to replace or supersede any terms and conditions or data sharing agreements we may agree with you.
- Important Information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International Transfers
- Data security
- Data retention
- Your legal rights
Appendix 1: Data processing statement
1. Important information and who we are
Purpose of this privacy notice
This privacy notice explains how we collect and process your personal data when you interact with us, including any data you may provide through this website. It also explains how we’ll store and handle that data, and keep it safe.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
JWB Consulting is the Data Controller for any personal data you provide to us when engaging us directly or through use of our website. (referred to as "we", "us" or "our" in this privacy notice).
- call us: 01522 721277
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 10 May 2018. It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites and resources. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. If you provide a passport or driving licence to prove your identity (for example in order to obtain finance with us), the data will also include your place of birth, facial image and nationality. Your image may also be recorded on CCTV when you visit one of our shops or car parks.
- Contact Data includes email address and telephone numbers
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, notes from our conversations with you, details of any complaints or comments you make, items viewed or added to your basket, web pages you visit and how and when you contact us.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless it is strictly necessary in order for us to provide our services. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. When and how we collect your personal data
- Direct interactions. You may give us your Identity, Contact, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- request marketing to be sent to you;
- book any kind of appointment with us or book to attend an event (for example an ice skating session);
- enter a competition, promotion or survey;
- give us some feedback;
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing
including basis of legitimate
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To manage our relationship with you which will include:
(b) Sending you legally required information relating to your orders or information about product recalls.
(c) Asking you to leave a review or take a survey
(d) Responding to your queries, refund requests or complaints.
((e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to provide you with the best service and to understand how we can improve our service based on your experience)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you; send you relevant communications by post in relation to updates, offers, services or products; measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy and to run our loyalty scheme)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|For credit check and fraud management||(a) Identity
|(a) Necessary to comply with a legal obligation.
(b) Necessary to perform a contract with you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside JWB Consulting for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for legal, compliance or accounting purposes. Such disclosures will be limited to only that which is required and necessary to fulfil our obligations.
6. Data security
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We have put in place appropriate physical and technical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, we ensure that all physical data storage units can be securely locked and remain on our business premises at all times.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
- Access to the personal data we hold about you, free of charge in most cases.
- Correction of your personal data when incorrect, out of date or incomplete.
- Erasure of your personal data for example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- That we restrict the way we process your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- That we transfer your personal data to a third party by providing to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
- give us some feedback;
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Appendix 1: Processing Statement
This statement is prepared by JWB Consulting (‘we’, ’us’ or ‘our’) in our capacity as a Data Processor as defined under the General Data Protection Regulations.
The purpose of this statement is to assure our current and prospective customers and clients (‘you’) that we have adopted appropriate processes, procedures and measures to ensure ongoing compliance with Data Protection legislation.
This statement is for information purposes only and is not intended to create any binding legal obligations between us and you.
1. Our Compliance with GDPR:
Information we hold: Due to the nature of our business, we do not routinely request, receive, retain, use or store personal data relating to individuals. We provide education and learning services to students and learners on behalf of educational organisations or local authorities on a contractual basis.
We do not require the personal data of the individual students or learners in order to carry out our contractual duties to the Data Controller. There may be scenarios where we are presented with registers, sign-in sheets or basic demographic data to monitor attendance for the Data Controller, but at no point do we retain or copy this data for our own records. Any such original documentation or data will be promptly returned at the conclusion of our work.
There may be cases where we are provided sensitive category data, such as disability data, to enable us to carry out our services effectively and with respect to the individual concerned. This is necessary to perform our contractual services, but as per the above we do not retain copies of this data.
Accountability & governance: This Processing Statement forms part of our Privacy Notice which explains, to our customers and staff alike, our stance on protecting personal data.
We ensure that our staff have the necessary level of training required to enable them to carry out their duties in compliance with data protection law. This training is updated, refreshed and renewed from time-to-time.
In the unlikely event of a personal data breach occurring, we have procedures in place to record details of the breach and report these to you, subject to any specific requirements as may be stipulated in our Terms of Business or Data Sharing Agreements with you.
Individual Rights: We fully understand that the rights of each individual data subject are paramount under Data Protection laws.
Where possible we will respond promptly to any request for access, rectification or erasure from a data subject after suitable ID checks have been carried out on the individual making the request. We will also reasonably assist our Data Controller with any such requests. It is however very unlikely that we will have any personal data retained on our files.
2. Technical and Organisational Security Measures:
We have carried out an audit of our business to identify what types of data we hold on file so that we can implement suitable security measures which are proportionate to the volume and sensitivity of the data we process.
As our business deals mostly on a business-to-business basis, the security measures required are fairly minimal. Nonetheless, we have already taken steps to ensure any physical data is always stored securely within a locked document storage unit or filing cabinet on our premises, which only the senior personnel of our business has access to.
We regularly use laptops, computers and mobile phones for communicating with our business contacts and exchanging emails. We have chosen forms of technology for this purpose which allow us to remotely delete all data from the device in the event of those devices being lost or stolen.
We are actively considering any further level of security that may be required for our business, but we are satisfied that the measures so far implemented are sufficient and reasonable.
3. ICO Registration & Accreditations
As an organisation that acts solely as a Data Processor, we are not currently required to register with the Information Commissioners Office (‘ICO’). However, we will be so registered as a sign of our commitment to ensuring good data protection practices in our business.
We are currently awaiting the implementation of the General Data Protection Regulations to see how this system may change going forward. We will ensure that we have any and all registrations that are required by law.
We are not an organisation that requires accreditation or authorisation from a regulatory or supervisory body to carry out our business, but we do ensure that we have enhanced DBS checks to carry out our services with potentially vulnerable students and learners.