GDPR PRIVACY POLICY

Welcome to the CAMOR privacy policy.

Camor respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website or when we provide you with our training services and tell you about your privacy rights and how the law protects you.

1.   INTRODUCTION

Welcome to CAMOR's privacy policy. At CAMOR, we care deeply about privacy. We believe in transparency, and are committed to being upfront about our privacy practices, including how we treat your personal information. CAMOR respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website or when we provide you with our training services and tell you about your privacy rights and how the law protects you. This policy has been compiled to ensure compliance with GDPR regulations.

 

2.   IMPORTANTINFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data, including any special category personal data.

This website is intended for course delegates, partners, visitors to our website, clients, and any other persons from whom we may collect personal data.

This policy ensures that we meet the Data Protection Principles which require us to ensure that personal information we collect shall be:

·        Handled fairly and lawfully

·        Kept and used only for limited purposes

·        Required for a valid legal reason

·        Correct and up to date

·        Handled confidentially

·        Stored securely

·        Not transferred to unapproved countries outside the European Economic Area (EEA)

 

Who we are

CAMOR Limited  is a security consultancy and  a provider of specialist security training. We are the controller and responsible for your personal data (collectively referred to as “CAMOR”, "we"," us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: CAMOR Limited (company numberSC561319)

Email address: sroberts@camor.co.uk

Postal address: Eskmills, Stuart House, Station Road, Musselburgh, EH21 7PQ

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.

Your acceptance of this privacy policy and our right to change it

By receiving or signing up to our services, using our website or by providing your personal information, you understand that we will collect and use your information in the ways set out in this policy. If you do not agree to this policy please do not use our website or services.

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.

We may make changes to this privacy policy from time to time. If we do so, we will post the changes on this page and they will apply from the date on which they are posted.

Third-party links

This website may include links to third-party websites, plug-ins and applications. 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 policy of every website you visit.

 

3.   THE DATAWE 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 as follows:

We collect personal data directly from you, or from your employer, during programme recruitment and induction, this includes:

Personal information such as your name, date of birth, gender, details of your current employment and job role, qualifications and where appropriate your contact details.

We will collect information you voluntarily provide us with when you contact us with queries, complaints or feedback regarding our services.

We may collect information relating to your health, such as any hearing impediment, dyslexia, epilepsy, or any other medical condition which may require an adjustment to our ICT equipment to allow us to properly and appropriately provide our training services to you. We may also collect information relating to ethnicity through our Equality and Diversity monitoring forms for students.

Subject to the above paragraph, 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). Nor do we collect any information about criminal convictions and offences.

If you visit our website, we may automatically collect the following information:

Technical and usage data, which includes internet protocol(IP) address, 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; and information about your visit to our website such as page response times, lengths of visits to certain pages, page interaction information and methods used in browsing away from the site.

For further information, please see our Cookie Policy.

Other sources of personal data

We may also obtain personal data from other sources, such as specialist companies that provide information, social media, and public registers and public website domains.

 

4.   HOW WEUSE 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 the contract we area bout to enter into or have entered into with you or with your employer or organisation.

·        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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. 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.

Purposes for which we will use your personal data

Depending on your relationship with CAMOR, we need to collect, hold and process personal data about you in order to:

·        Where you are a course delegate: confirm your identity and role in your organisation to register you on a course, to deliver the training to you, and to keep in touch with you for example to deliver course information, and where appropriate we may require details of any specific needs in respect of your health conditions or to make provision for a disability and provide you with the appropriate support.

·        Where you are a client: enter into and perform our contract with you, manage payment and accounts, communicate with you regarding our services or to provide information in response to a query, to meet our legal obligations (for example in relation to tax administration) and to respond to complaints and client feedback.

·        Where you are a supplier, partner, professional advisor or other third party: enter into and perform contracts and engagements, to comply with our legal obligations or for our legitimate interests or those of another party.

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.

Please be advised that we do not use any automated decision mechanisms in relation to personal data.

 

5.   DISCLOSURESOF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out above.

·        Delegate data will be shared with your employer or organisation in the performance of our contracts with our clients. Your employer or organisation is also a data controller in relation to your personal data.

·        Where relevant to a course, data will be shared with external consultants and training providers who are delivering training on our behalf.

·        In certain circumstances we may share personal data with our professional advisors or with HMRC or other government bodies and with qualifications agencies and assessment organisations.

·        Data will be visible to service providers who provide CAMOR with support and other services essential to the functioning of our business. These persons will be data processors, and at the date of this policy, are the following third parties:

o   Company Accountants;

o   Website Provider;

o   SQA; and

o   Glasgow Caledonian University.

·        In the event of a change to our organisation, personal data will be shared with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6.   HOW WEPROTECT YOUR PERSONAL DATA

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.    HOWWE STORE PERSONAL DATA AND THE PERIODS FOR WHICH WE STORE IT

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your employer or organisation.

In some circumstances you can ask us to delete your data: see Section 8 (Your legal rights) below for further information.

 

8.    INTERNATIONALTRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

 

9.    YOURLEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

·        Request access to your personal data(commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

·        Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·        Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·        Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

·        Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o   If you want us to establish the accuracy of the data.

o   Where our use of the data is unlawful but you do not want us to erase it.

o   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.

o   You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

·        Request the transfer of your personal data to you or to a third party. We will provide 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. if we received your personal data from your employer or organisation with whom we have contracted to provide our services, then this right may not be available to you.

·        Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at sroberts@camor.co.uk.

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 could 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 from the day on which we receive a request. All requests will be considered carefully, and we will endeavour to comply with all legitimate requests so far as possible. Occasionally it could 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.

Policy Review

This policy will be reviewed as appropriate and updated when required.