Bound to Prosper (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This policy, together with any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Our address is as follows:
86-90 Paul Street
Our website is www.boundtoprosper.com is owned and operated by Bound to Prosper.
We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.
The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).
Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
Under the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR') and Data Protection Act 2018 ('the Act'), personal data is defined as 'any information relating to an identified or identifiable natural person ('data subject'), 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'.
THE DATA CONTROLLER
A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. Bound to Prosper is the data controller as defined by relevant data protection laws and regulation.
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever personal data is to be processed:
(a) Consent: you have given Bound to Prosper your freely, specific, informed or unambiguous consent for your personal data to be processed for a specific purpose.
(b) Contract performance: the processing is necessary for the performance of a contract you have with Bound to Prosper, which had asked you to take specific steps before entering into a contract.
(c) Compliance with legal obligation: the processing is necessary for Bound to Prosper to comply with the law for tax, social security obligation, employment law purposes (not including contractual obligations).
(d) Protection of vital interests: the processing is vital to an individual's survival.
(e) Public interest: the processing is necessary for Bound to Prosper to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for Bound to Prosper legitimate interests, or the legitimate interests of a third-party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.
DATA SUBJECT RIGHTS
Your data subject rights are listed below:
· the right of access.
· the right to rectification.
· the right to erasure or right to be forgotten.
· the right to restriction of processing.
· the right to be informed.
· the right to data portability.
· the right to object.
· the right not to be subject to a decision based solely on automated processing.
Under the GDPR and the Act, you may ask for a copy of the information we hold about you and you may request rectifications be made to this information if it is inaccurate or not up to date. Please write to Data Controller at Bound to Prosper
PERSONAL DATA WE COLLECT
We collect personal data for different purposes, therefore, we outlined below:
1. Professional Services
We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data to satisfy a contractual obligation. We request that clients only provide the personal data that is required for us to fulfil our contractual obligation.
Why do we process this data?
Where data is collected for professional services, it is used for a number of purposes, as follows:
· Providing services to clients, data is processed in accordance with our letter of engagement between our clients and us and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of professional services to our clients, which includes;
· Client management, when communicating with and assessing the needs of clients, personal data may be processed to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services is provided to our clients are appropriate.
· To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, journalist and blogger personal data, administering client facing applications, and maintaining internal operating processes.
· To undertake professional services, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.
What kind of data is processed?
The data that is processed is dependent on the service that is being provided and on the recipient of this service.
· Services to businesses, non-profits, and other organisations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services. As an example, this may include contact details, payroll data, employee information (including details about dismissal), lists of shareholders, customers and suppliers and any other specifically relevant data.
· Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.
2. Business Contracts
Personal data from our contacts, which covers both potential and prior customers, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool).
This information is entered into the system after contact is made between a staff member of Bound to Prosper and a business contact. Some contacts are held who haven’t been made contact with as yet, but we believe there is a legitimate business interest.
We use technology profile our business contacts, so that we can assess the health of our relationship with our business contacts. We will rely on the appropriate condition for processing data.
Why do we process this data?
Where personal data on business contacts is held, it is used for a number of purposes, as follows;
· Promote and develop our offerings.
· Communication of technical updates.
· Hosting and facilitating of events.
· Relationship management.
· Administration and management.
For promoting our services, we may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
What data do we process and hold?
Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
3. Our people
We collect personal data for our people as part of the administration, management and promotion of our business activities.
Our staff handbook and partnership deed explain further how personal data is held for our staff and partners.
Where an individual is applying to work for Bound to Prosper, personal data is collected through the application process. Data is often collected through forms on the website, details of which can be found in the section describing people who use our website. Data collected via the website will be used for the purposes detailed below.
There are several purposes that personal data for applicants are collected, including:
· We process an applicant’s personal data to assess their potential employment at Bound to Prosper.
· Administration and management. We may also use this personal data to make informed management decisions and for administration purposes.
Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.
We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.
Why do we process this data?
· Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
· Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
· Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
- managing our relationship with suppliers;
- developing our businesses and services (such as identifying client needs and improvements in service delivery);
- maintaining and using IT systems;
- hosting or facilitating the hosting of events; and
- administering and managing our website and systems and applications.
· Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
· Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
· Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.
What data do we process and hold?
We will hold supplier’s names, contacts names, and contact details of suppliers.
We have security in place at our offices, for the physical security of client information and for the benefit of our staff.
Why do we process this data?
Building access controls and may require visitors to our offices to sign in at reception and keep a record of visitors. This is retained in case of theft or other incident and to protect the staff and information in the office.
What data do we process and hold?
Our visitor book may include name, business, times and car registration.
5. Collection of data by our website
When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps. In addition, personal data and information may also be collected via the agency’s social media feeds and content linked to the website.
Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry, comment on publications, enter a competition, promotion or survey, apply to work for a Bound to Prosper business and report a problem with our websites.
When individuals visit our websites, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.
Why do we collect this data?
There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;
· In to administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimised appropriately.
· In order to allow individuals to use some functionality of our website, certain personal data must be entered in order for features to work as intended.
· In order to keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
· Promote and develop our offerings. Some personal data may be used in order to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.
What data do we process or hold?
The data that we hold depends on what data was entered and for what purpose.
Where data was entered in order to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, personal description and photograph.
Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies to gather information about you from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers and news archives.
We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations. This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. If you would prefer us not to use your data in this way, please email us at firstname.lastname@example.org
SHARING YOUR PERSONAL DATA
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals. This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we have to comply with as well as those organisations with whom you and we have reciprocal agreements for providing services for education or professional development.
Personal data held by us may be transferred to:
Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.
Third party organisations that otherwise assist us in providing goods, services or information
Bound to Prosper and group businesses.
Auditors and other professional advisers
Law enforcement or regulatory agencies or those required by law or regulations
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
THIRD PARTY WEBSITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
PROTECTING YOUR PERSONAL DATA
Where possible, personal data resides within the UK. It may also be processed and stored within the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.
If personal data is transferred outside the UK or EEA to a country without a designated adequacy rating, Bound to Prosper will request the data subject's consent before processing the data. Consent will not be sought where the processor's Binding Corporate Rules, Standard Contractual Clauses or adhoc contractual clauses stipulate that the data will be processed in accordance with the GDPR.
SECURITY OF YOUR INFORMATION
To help protect the privacy of data and personally identifiable information you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
HOW LONG WE STORE YOUR PERSONAL DATA FOR
We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
Furthermore, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
In light of the data of people who visit our offices, such records are accessed on a need to know basis only. Any CCTV recordings from outside the main building are typically overwritten after a short period of time unless we identify an issue requiring investigation.
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will investigate and respond to any complaints we receive.
For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
Information Commissioner's Office
Tel: 0303 123 1113 (local rate)