Privacy Statement

We may also collect, use and share Aggregated Data such as statistical or demographic data which we collect from interactions with our cilents. Aggregated Data may be derived from Personal Data but since it cannot be used to identify an individual, it is not Personal Data.

• We hold and process some personal Data as a Controller, which means we must have a ‘lawful basis’ for doing so.
• Anywhere we are relying on legitimate interest we believe that such processing is necessary for the purposes of our legitimate interest, which in this case is to function as a business. We consider such use goes no further than the Data Subject would reasonably expect; is likely to align with the Data Subject’s interests (by enabling us to provide a sustainable business model) and is unlikely to be detrimental to the fundamental rights and freedoms of the Data Subject.

6. If you have any questions about who your data might be transferred to please send us an email at cara.mccann@hereni.org

7. It is our policy to ensure that all Personal Data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.

Our retention policies for are as follows:

• We may store data related to financial transactions for up to 6 years to ensure that we have sufficient records from an accounting and tax perspective;

• We may archive data relating to negotiations, contracts agreed, payments made, disputes raised and your use of our software for up to 10 years protect ourselves in the event of a dispute arising between you and us;

• We may store aggregate data without limitation (on the basis that no individual can be identified from the data).

9. Data Subjects have the following rights in respect of Personal Data relating to them which can be enforced against whoever is the Controller.

• Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it’s used.

• Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:
• The purposes of the processing;
• The categories of personal data concerned;
• The recipients to whom the personal data has/will be disclosed;
• For how long it will be stored; and
• If data wasn’t collected directly from the Data Subject, information about the source.

• Right of rectification: the right to require the Controller to correct any Personal Data held about the Data Subject which is inaccurate or incomplete.

• Right to be forgotten:  in certain circumstances, the right to have the Personal Data held about the Data Subject erased from the Controller’s records.

• Right to restriction of processing: the right to request the Controller to restrict the processing carried out in respect of Personal Data relating to the Data Subject. You might want to do this, for instance, if you think the data held by the Controller is inaccurate and you would like to restrict processing the data has been reviewed and updated if necessary.

• Right of portability: the right to have the Personal Data held by the Controller about the Data Subject transferred to another organisation, to the extent it was provided in a structured, commonly used and machine-readable format.

• Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose).

• Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on the Data Subject.

If you want to avail of any of these rights, you should contact us immediately at cara.mccann@hereni.org. If we are not the Controller, we will need to transfer your request to the Controller – but we will only do so with your consent. If you do contact us with a request, we will also need evidence that you are who you say you are to ensure compliance with data protection legislation.

10. If we are holding Personal Data about you as a Processor, we will need to transfer your request to the Controller who has engaged us to provide our Services.

10.1. If we are holding Personal Data about you as a Controller, we will comply with your request unless we have reasons for lawfully retaining data about you.

10.2. If we are holding Personal Data about you and using that data for marketing purposes or for any other activities based on your consent, you may notify us at any time that you no longer want us to process Personal Data about you for particular purposes or for any purposes whatsoever and we will stop processing your Personal Data for that purpose. This will not affect your ability to receive our Services.

11. If you have any questions or concerns about how we are using Personal Data about you, please contact our Data Protection Officer immediately at our registered address (see paragraph 10.1 above) or by email to cara.mccann@hereni.org. If we are processing Personal Data about you on behalf of an other organisation, we will need to pass your complaint to their designated person – we will only do so with your consent.

12. If you wish to make a complaint about how we have handled Personal Data about you, you may lodge a complaint with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/.

13. Throughout this notice you’ll see a lot of defined terms. Where possible, we have tried to define them as we go, but we thought it might be useful to have a glossary at the end for you. Anywhere in this notice you see the following terms, they’ll have the following meanings:

Controller is a legal term set out in the General Data Protection Regulation (GDPR), it means the party responsible for deciding what Personal Data to collect and how to use it;

Data Subject means the individual who can be identified from the Personal Data;

Personal Data means data which can be used to identify a living individual. This could be a name and address or it could be a number of details which when taken together make it possible to work out who the information is about. It also includes information about the identifiable individual;

Processor is another legal term set out in the GDPR, it means the party who has agreed to process Personal Data on behalf of the Controller; and

Special Categories of Personal Data means details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

Last updated: 23rd May 2018