We will be transparent about the information we are collecting and what we will do with it.
If you tell us, you don’t want to receive marketing messages we will stop sending them.
We will put in place measures to protect your information and keep it secure.
We will respect your data protection rights and aim to give you control over your own information.
What do we mean by personal information?Personal information means details which identify you or could be used to identify you, such as your name, address and contact details. It may also include information about how you use our websites and mobile applications.
When do we collect personal information about you?We collect personal information about you whenever you use our services, including when you use our website, or interact with us via email or use our customer services.
What types of personal information do we collect and retain?We collect the following categories of personal information:
- Information you provide for WHS to complete a service you have requested from us.
- Information about the services we have provided to you in the past.
- Information about online registration and other interactions.
- Information about your use of our website
What do we use your personal information for?The main purposes for which we use your personal information are:
- To fulfil and deliver the services you have asked for.
- To carry out analysis and market research.
- To carry out marketing including online advertising and keep you informed of WHS products and services.
- To improve our website, products and services.
When will we send you marketing?When we collect information directly from you, we will ask you if you would like to receive our marketing communications. Please be aware that we do not transfer your data to third parties. We will respect your choice as to what communications you wish to receive and how these are sent.
How can you change what marketing communications you receive and how you receive them?If you decide you would no longer like to be sent marketing communications, you can change your mind at any time by emailing email@example.com.
In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop receiving further marketing emails.
We aim to action requests to stop being sent marketing communications within 21 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made.
Please note that if you ask us to stop sending marketing communications, we will retain your personal information for the purposes of indicating that you do not want to receive marketing communications.
What is our legal basis for using your personal information?WHS will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reasons WHS collected and need to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:
- Because we need to use your information so that we can process your enquiry.
- Because it is in WHS’s legitimate interests as a service provider to use your personal information to operate and improve our business.
- Because WHS needs to use your personal information to comply with a legal obligation.
- Because you have consented to WHS using your information for a particular purpose.
If the processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How long do we keep personal information?We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you respond to a marketing campaign, we will keep the information, for a period which enables us to fulfil that campaign.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 2 years.
Legitimate InterestsAs a service provider, WHS has a legitimate business interest to use the personal information we collect to offer an effective service and carry out our business.
Compliance with legal obligationsThere are situations where WHS is subject to a legal obligation and needs to use your personal information to comply with those obligations.
To protect the vital interest of you or another person
There are situations where we may need to use your personal information to protect the vital interests of you or another person.
ConsentAlternatively, we may collect and use your personal information where you have given your specific consent to us doing so.
If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time by emailing firstname.lastname@example.org.
However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or part of the services you have requested from us.
Who do we share your personal information with?WHS will not sell personal information to third parties or transfer data outside the EU.
What are your legal rights in relation to the personal information we hold about you?Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated, we may extend the deadline for responding to three months, but we will let you know if this is the case.
We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.
Details of how to exercise your rights are set out in the section below “How can you exercise your legal rights and change how we use your data?
Your rights include the following:
You may request us to stop sending you marketing. To see how to change your permission to market please refer to “How can you change what marketing communications you receive and how you receive them?” which can be located in “When will we send you marketing?”. If you do so we will no longer be able to send you marketing communications.
You may request us to stop using your personal information where we are doing so under legitimate interests (see the section “What is our legal basis for using your personal information”) unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.
You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising.
You may access the personal information we hold on you.
There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see “Accessing your personal information” which can be located within “How can you exercise your legal rights and change how we use your data?” for more details.
You may ask us to correct your personal information (the ‘right of rectification’) if that information is inaccurate by emailing email@example.com outlining the action to be taken.
You may ask for personal information which identifies you to be erased (or forgotten).
To do this we will remove the information that identifies you from the data we hold in our active systems (“anonymise”). However, a separate and restricted copy of the identifying information will be kept for 2 years to meet the obligations we have to law enforcement, national authorities and legal proceedings.
In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us.
We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you.
How can you exercise your legal rights and change how we use your data?If you wish to change how we use your personal information, please email firstname.lastname@example.org. We will ask for some information to identify you, which will only be used to process your request. We will verify your identify via email before processing your request.
Accessing your personal informationIf you wish to receive a copy of your information, you can make your request in writing and include the following information with your request:
- Your name and postal address
- Details of your request
- A photocopy of your passport, so that we can verify your identity
- Your signature and the date of the request
- If you are applying on behalf of another person then signed authority from the individual is required
- Any details which may help us locate the information which is the subject of your request.
How to get in touch with us and your right to complain?If you have any questions about this policy, please contact the Data Protection Officer.
The Data Protection Officer for WHS can be contacted at email@example.com.
We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact the WHS Data Protection Officer who will address your concerns.
We hope that we will be able to resolve any concerns you may have.
However, you have a right to complain to the UK’s Supervisory Authority for data protection, the Information Commissioner at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF