The Privacy Notice below describes how your data is collected and used.
Over time the Privacy Notice has been updated. I only update the Privacy Notice when I feel that wording could be improved (or new wording added) to make things more transparent or where the website setup changes (or where the law changes)*.
I will never change the Privacy Policy retrospectively to retain more data, but please read the info below as regards the most recent changes/additions to the Privacy Policing wording*. Please check this page regularly, as changes/additions may be made over time. My aim is always to improve the Privacy Notice.
*Please note that changes/additions to the Privacy Policy have been made over time, for example, when social media pages were created or when my website (or its setup) was changed. Wording has also been changed/added to on occasions to try and make it as clear as possible how data is used. Put simply, if I think my wording could be improved, I change it (or add to it) to try and make things clearer.
The most recent changes/additions/notes for information are mentioned below.
* Note added on 05/11/2024 to clarify disclosing emails etc to tax authority. (Also bullet points improved under legitimate interest but wording there not changed).
*Small amount of additional wording added to virus scans, etc. (towards bottom of page) on 24/08/2024.
*Note to clarify point on exception to retention period added on 03/08/2024 (& subsequently added to on 04/08/2024) (where indicated in the section of "How long I will retain your information") (Plus additional small notes added 05/08/2024).
*Note: Introductory wording amended 14/04/2024.
*Note: Error on ICO website address corrected 14/04/2024 (at bottom of page).
*Note added 09/04/2024 (& subsquently amended 10/04/2024 & 13/04/2024) regarding virus scans, etc. (see below (towards bottom of page)).
*Note added 11/05/23: If you previously attended a group art session your data is being held in the same way as someone who booked more traditional tuition (in a subject I offered private tuition in, as I only offered group sessions for art). Please read this Privacy Notice (as appropriate) in light of this. (Although there has been no group art session since November 2020 and none will be run in the future and there was a Privacy Notice at the time specifically dealing with group art sessions this note has been added for clarity).
*Note added 04/12/23: If you did law tuition your data is being held as per the Privacy Notice. (Although there has been no law tuition since mid-January 2021 or thereabouts and there will not be any in the future, this note is here for clarity). (For info: The web address of the Privacy Notice that was on my previous site automatically redirects to this Privacy Notice).
*The most recent changes concern the use of diaries (previously making appointments was mentioned, but not specifically diaries). I appreciate that it probably is obvious to customers that I use a diary, but I added details for completeness. Also text messages have been expressly mentioned (although these would have come within the meaning of "correspondence" previously). A note on storing phone numbers on my mobile has also been added. A note clarifying what emails, text messages, etc. are kept has also been added. Notes taken from telephone calls and messages have also been mentioned. Timescales for retaining data, unless stated otherwise, however have never been changed. If you have any questions feel free to ask me. (Note added 15/02/2022)
**Note added for clarity 17/03/22: “Bank statements” referred to anywhere on this page includes building society statements and Paypal statements (as appropriate).
***Note added for clarity on 22/08/22 (& 23/08/22) regarding profile/listing on Google my Business/Google Maps. Added just for info (see further below for details).
Who I am (The Data Controller as well as the service provider information)
The data controller and service provider is Adam Wardle of 43 Miller Drive, Fareham, Hampshire PO16 7LY who trades as a sole trader (Email: This email address is being protected from spambots. You need JavaScript enabled to view it.).
All services are provided (and all advertising is conducted) by Adam Wardle of the above address as a sole trader.
For information, to advertise tuition and related services he has a Facebook page (currently named "helplearncom"), a Twitter page (currently named "helplearncom") and this website (which may be referred to in advertising and correpondence as the url address or a shortened version of it e.g. www.help-learn.com, help-learn.com, etc.).
***Note added 22/08/2022: For info I also have a profile/listing on Google my Business/Google Maps. I do not use Google my Business/Google Maps to process personal data* (with the exception of keeping records of Customer Reviews, as detailed previously: see further below for details relating to Customer Reviews). This note has been added for completeness. (On a separate note, the use of data in relation to other Google services and your use of this website, etc. however is detailed further below).
*With the exception of Customer Reviews, on Google my Business/Google Maps I only have anomymised data on visitors to my profile/listing on Google (e.g. number of people who clicked on post, number of people who clicked on link, etc.). Google however does collect data from visitors who use its services. See policies.google.com/privacy for details. (As mentioned above on a separate note, the use of data in relation to other Google services and your use of this website, etc. is detailed further below): Note added 23/08/2022
Any logos used are (unregistered) trademarks and may include the words "Help Learn" which is named after the website address (or alternatively may refer to the website as previously detailed here).
All activities are carried out by Adam Wardle of the above address as a sole trader.
Who I hold information on
I hold personal data on:
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People who contact me
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Customers
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People who visit my website
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People who use contact me via my social media pages (Facebook. Twitter, etc.) or Whatsapp
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People who communicate with me through Skype (i.e. usually during tuition sessions)
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People/Companies I use for business services (e.g. advertising)
How I receive your information
Information I have about you comes from us getting in contact with each other. Normally this is by you emailing me with an enquiry or booking with me, but it could be by you phoning me or booking through a third party website.
You could alternatively provide me information through one of my social media pages (Facebook, Twitter, etc.), your use of Skype (i.e. usually during tuition sessions) or your use of this website.
What kind of information I may hold about you
For the majority of customers the only personal information I hold is name, address, email address and possibly telephone number.
Please note that depending on how you pay me your details can appear on my bank statements* against your payments (e.g. if you pay by bank transfer your name/account details may appear on my statements).
*Note added for clarity 17/03/22: “Bank statements” includes building society statements and Paypal statements (as appropriate).
I may hold additional information from your use of the website (or where you contact me or leave information on one of my external Social Media pages or Whatsapp). Please see:
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‘Cookies/Website/Google Analytics/reCAPTCHA’
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‘Information relating to social media sites’; and
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‘Information relating to Skype‘
all of which are below.
Why I collect this information
The personal data is necessary for me to:
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deal with customer enquiries (e.g. someone emails about tuition, so I email back with a quote);
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provide my services to you under the terms of our contract (e.g. book appointments etc.);
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comply with my legal obligations, for example tax (e.g. I write down your name and address on my accounts against a payment you make me, as the tax authorities require me to record who I receive any payments from); and
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deal with enquiries in relation to payments
Where you wish for a written quotation, I cannot do so without your basic contact details (e.g. an email).
Without your name and address I cannot provide you with tuition.
The legal basis for processing your information
I need to process information for the following reasons:
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The performance of the contract with you or for me to take steps for me to enter into a contract
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This covers situations such as where someone makes an enquiry with a view to booking tuition, I may use their email address to email back with a tuition offer.
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This also covers situations such as where someone with an existing contract emails me about tuition and I email back.
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This also covers things such as me booking appointments. Please note that this is done using a diary.
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The perfomance is in compliance with a legal obligation, such as providing information to a tax or other authority
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This covers situations, such as where I record personal details on my accounting records to show where payments have come from. Like any other business I am required by law to keep full detailed accounts. This includes providing details on who I receive payments from as well as details of any refunds I make.
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HMRC requires me to retain details relating to payments received and refunds made to prove the authenticity of my accounts (for example correspondence in relation to refunds I make).
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I also may need to provide copies of my bank statements* to HMRC, which show payments in from you (and payments made to you, for example, in the event of a refund).
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**Note added for clarity 17/03/22: “Bank statements” includes building society statements and Paypal statements (as appropriate).
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- Although it is unlikely, I may possibly need to provide evidence to HMRC of cancellations, contract terms or other correspondence between us if required by them. In this event this may involve showing emails from customers to HMRC. (Note added 05/11/2024: For clarity this point was written to make people aware there is a small possibility email correspondence etc between me and a customer may need to be shown to a tax authority in certain circumstances. This would essentially be complying with a legal request of a tax authority. However details on what data including correspondence etc is retained is dealt with elsewhere in this Privacy Notice and is not dealt with by this point as such).
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Regarding Coronavirus impact: Please note that HMRC has previously announced that businesses making any claims relating to Coronavirus impact are required to retain evidence of Coronavirus impact. This does not make any difference to data being retained, but it means that HMRC may (possibly) ask for and require sight of customer correspondence, such as customer emails cancelling tuition because of the Coronavirus situation.
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The performance is in relation to a legitimate interest:
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I keep customer reviews (typically emails) so that their authenticity can be verified.
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I may store phone numbers on my mobile phone to enable me to communicate to people when required.
- I store correspondence relating to contracts in case of a later query or complaint. Diaries (with details of appointments and brief notes re payments received/refunded, etc. (but NO bank details, etc.) are also stored for this purpose.
- To be clear, almost all emails (and text messages) between me and customers relate to a tuition contract, because they either relate to the agreement itself (its terms) or arrangements that affect the performance of the contract.
- The same applies as regards notes of phone messages and calls.
- To be clear, almost all emails (and text messages) between me and customers relate to a tuition contract, because they either relate to the agreement itself (its terms) or arrangements that affect the performance of the contract.
- I may need to show an accountant doing services on my behalf accounts records, correspondence supporting any financial claim, etc.
- If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). As a result, I may need to present some bank statements* to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements* show the names of the people who paid me, which is personal data).
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*Note added for clarity 17/03/22: “Bank statements” includes building society statements and Paypal statements (as appropriate).
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- Virus scans are done under the ground of legitimate interest (further details below): Note added 13/04/2024.
I do not do mailing lists, etc.
I do not do mass marketing emails, etc.
Visitor Record
When art was running a record of all visitors was made during each session, as this was required by the hall for their insurance purposes. The visitor record for each session is being kept for up to six years and ten months from the date when the relevant session took place.*
* Please note this included a record of who was physically present at sessions, left early, etc. in case of a fire, etc. (required by insurance as well as the hall for safety reasons).*
* Although no new records are being created now, because sessions are no longer taking place (and will not take place in the future), it was decided to retain this information here for people who used to do sessions. The wording has been updated to reflect the fact that this was being done in the past, but the substance of the wording has not been changed.
Information relating to social media sites
With the exception of private messages you send me through a social media account, my social media accounts are by their very nature public. Consequently when you submit any information, ‘like’ a page/article/comment or leave a comment, etc. on any of my social media accounts, by its very nature you are making that information/action you take public. Usually such information stays on my public social media pages indefinitely (e.g. liking a page, leaving a review, commenting on a post I make, etc.).
As the social media services are public anyone can look at them, so any information or action you make public will be available for anyone to see. I cannot control how other people use that information. In short, if you are not happy for anything you do on the social media accounts to be made public, please do not do it in the first place.
Retention periods in relation to Facebook, Twitter and Whatsapp
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The individual social media services (and Whatsapp) will have their own Privacy Policies which you should be aware of. I have no control over their Privacy Notices and their retention of data.
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As regards notification emails, these fall into two groups:
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Email notifications I receive giving details of customer reviews I may keep indefinitely. This is under the legal ground of legitimate interest, as I may need to prove the authenticity of reviews in the future.
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Other social media notification emails will be deleted by me within a maximum of one year (with the exception of where I am required to retain them by law (e.g. court order), in which case they will only be kept for so long as the law requires me to do so).
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As regards private messages received through an account*:
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These will be deleted within a maximum of one year with two exceptions:
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1. Where you book tuition within a year (or already have a contract with me), the message (and/or a copy of the message) may be kept by me for a maximum of six years and ten months. This is done under the ground of legitimate interest, as I may need to deal with queries or questions relating to what was said/agreed or to deal with a possible complaint.
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2. Where I am required to retain the private message for longer by law (e.g. court order).
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* Please note that as at 21/02/22 10.05am I am currently storing no private messages to/from customers (or potential customers/past customers) on Facebook, Twitter or Whatsapp. The limited number of private messages previously kept on Facebook, Twitter and Whatsapp have been deleted, as I felt that I would be very unlikely to need the existing messages in the future. (Note: Messages sent and received in the future through Facebook, Twitter and Whatsapp however may be stored in accordance with the retention provisions above). - Note added 21/02/2022
Information relating to Skype
Skype has its own Privacy Policy which you should consult. Their retention of data is subject to their individual Privacy Policies over which I have no control.
The only data I technically have control over on Skype is your username, which may or may not be personal data depending on the circumstances. Using your username is necessary for us to be able to chat to one another.
Any information exchanged during Skype sessions is likely to be general in nature and related to, say, the language being learned, rather than personal data.
Previously I deleted customers from my Skype contacts (and consequently any conversations my end if not done automatically) within a year of completely finishing sessions. I kept these conversations for that one year on the grounds of legitimate interest. This was to enable me to deal with the unlikely event of a complaint.
From 31st March 2021 onwards I decided that one year is not long enough to retain records of conversations. This was extended with immediate effect on 31st March 2021 to six years and ten months for pre-existing and future conversations. This is done on the basis of legitimate interest, to enable me to deal with the unlikely event of a complaint. It is also felt necessary to retain records of conversations to support financial records of sessions taking place.
The reason for the change is prior to the Coronavirus situation very few sessions took place online, whereas now all sessions are online*. Obviously this may change in the future, but one year seems too short a time to support financial records. Customers whose conversations will be retained for longer than previously anticipated were contacted when the decision to change this was made.
*Note added 09/05/23 for clarity: Language tuition was offered in person only prior to the Coronavirus situation starting. (I however offered online (and in person) sessions in law prior to the Coronavirus situation starting. For info, law is a subject I stopped offering previously (approximately mid-January 2021 or thereabouts)).
Tax Deductible Expenses
This is unlikely to be of relevance to customers, but is included here for completeness. I am required by law to keep evidence of tax deductible expenses. I retain such documents for up to six years and ten months (unless required by law to retain them for longer e.g. court order, in which case I would not keep them longer than required by law).
Foreign Visa Applications
If I wish to go to some countries, I may need to apply for an entry visa in advance (e.g. tourist visa). This may mean I may need to present some bank statements* to the foreign embassy in advance of my trip and/or immigration officials on arrival to prove my financial standing and/or income. (Note: The reason for mentioning this is bank statements* show the names of the people who paid me against payments made, which is personal data). This does not affect the data that I retain, but is mentioned for completeness. Using data in this way (if ever it is) would be done under the ground of legitimate interest.
*Note added for clarity 17/03/22: “Bank statements” includes building society statements and Paypal statements (as appropriate).
Bank Statements*
For clarity, bank statements* which may have details of your payments are kept for up to 6 years and 10 months from the statement date. (Due to the nature of statements, each statement shows the previous months´ transactions therefore I may have details of transactions from up to 6 years and 11 months in the past). As detailed previously statements are kept, as they may be required by HMRC.
*Note added for clarity 17/03/22: “Bank statements” includes building society statements and Paypal statements (as appropriate).
How long I will retain your information
For details on the retention of i) my social media accounts and ii) Skype and iii) evidence of tax deductible expenses (unlikely to affect customers) please see the relevant sections above, but this section sets out the retention limits of all other data.
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*Note added 11/05/23: If you previously attended a group art session your data is being held in the same way as someone who booked more traditional tuition (in a subject I offered private tuition in, as I only offered group sessions for art). Please read this Privacy Notice (as appropriate) in light of this. (Although there has been no group art session since November 2020 and none will be run in the future and there was a Privacy Notice at the time specifically dealing with group art sessions this note has been added for clarity).
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Where you do not book tuition at all, data (e.g. emails, etc.) in relation to your enquiry may be kept for up to one year from the date when you last contact me.
Where you do book tuition, albeit at a later date, (or where you have paid for my details through a third party website), data (e.g. email enquiries, email correspondence, accounts records, mobile phone text messages, diaries, etc.) may be kept for a maximum of six years and ten months with the exception of:
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Correspondence with people continuing tuition on an ongoing basis.*
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Where someone is receiving tuition on an ongoing basis, documentation (e.g. emails) relating to the terms of the ongoing contract may be kept. (It would be very unusual for someone to be receiving tuition under the same contract for such a length of time). All other documentation will be retained (or deleted) in accordance with the other provisions of this Privacy Notice.*
*Note added 03/08/2024 & subsequently added to on 04/08/2024 (plus notes below dated 05/08/2024): To clarify, what this means is where a person is still doing tuition after more than six years and ten months period and there is documentation relating to the terms of the tuition contract that is still ongoing, this documentation (i.e. data) is retained whilst the person is continuing tuition even if that documentation is more than six years and ten months old. (This would be very unusual**). (The usual situation i.e. where someone does tuition for a period of six years and ten months or less, is this documentation is kept for a maximum of six years and ten months*** (as detailed above)). All other documentation (i.e. data) would be kept for the time period set out in the Privacy Notice (i.e. for a maximum of six years and ten months unless stated otherwise).-
**Obviously in reality it would be very unusual for someone to do tuition for as long as six years and ten months (or longer): Note added and amended 05/08/2024.
- ***For clarity, maximums are fixed. (They do not reduce, say, if you do tuition for a shorter period): Note added 05/08/2024.
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Customer reviews
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As regards customer reviews, I keep these indefinitely to prove the authenticity of these in the future.
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Where required by law
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This would cover the situation where I am required to keep documentation because of, for example, a court order.
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Cookies/Website/Google Analytics/reCAPTCHA
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
"Session" cookies and "Persistent" may be used on this website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.
The session cookies are used to: keep track of you whilst you navigate the website; prevent fraud and increase website security.
Persistent cookies are used to: enable the website to recognise you when you visit; keep track of your preferences in relation to your use of this website.
Blocking/Deleting Cookies
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer (version 9) you can refuse all cookies by clicking "Tools", "Internet options", "Privacy", and selecting "Block All Cookies" using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.
Google Analytics
Google Analytics is used by this site to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to this website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: policies.google.com/privacy.
reCAPTCHA
The contact forms on the site use reCAPTCHA, which is a service provided by Google. The idea behind it is to reduce spam being sent. The reCAPTCHA terms are at https://www.google.com/intl/en/policies/privacy/ and https://www.google.com/intl/en/policies/terms/. Links to the terms are on the relevant pages.
Links to external Sites
If you click on links to certain services or external sites, you will be using their services and be subject to their Privacy Policies. These are the links to Facebook, Twitter, etc.
Security measures in place.
– Encryption
– This site uses https instead of http
– Offline storage
Virus scans, etc.*
Like pretty much everyone with a computer I use anti-virus programs. I use Avast and Malwarebytes anti-virus programs with the aim of ensuring that my computer stays free from viruses. (The use of anti-virus programs is on the basis of legitimate interest**). Avast and/or Malwarebytes may scan emails, email attachments, other files, documents, programs, etc I have on my computer or access on my computer to ensure my computer stays virus free. The same also applies for devices such as my phone and my android device (although at the time of writing I do not access email that comes within the scope of this Privacy Notice*** on these devices). Full details of what these programs do and the privacy policies of Avast and Malwarebytes are at:
https://www.avast.com/en-gb/products-policy#antivirus
https://www.malwarebytes.com/legal/privacy-policy
*Note: Information added 09/04/2024 (& subsequently amended 10/04/2024)
**Note on legitimate interest added 13/04/2024.
***The words: "that comes within the scope of this Privacy Policy" added 24/08/2024.
Links to other sites/Contacting me through other sites
Essentially:
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Where my website has links to other websites, those sites are not covered by this Privacy Notice.
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Where you contact me through a third party site (e.g. Firsttutors) this Privacy Notice does not govern their retention of data provided by you on their site. (I cannot control what data an independent third party holds and how long they hold it for). In this scenario this Privacy Notice only governs data held by me (i.e. in my control).
Future changes to this privacy notice
It is possible that I will need to update this privacy notice in the future. In that event, I will update the Privacy Notice on this website. (Please be reassured that I will not increase time limits for retention of data retrospectively). Please look regularly for updates here, so that you are up to date on what information is collected and how it is used.
Your rights
You have the right to:
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request your personal data;
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object to processing of personal data that is likely to cause, or is causing, damage or distress;
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have inaccurate personal data rectified;
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request your information to be deleted or destroyed (Please note normally if I can I will, but I need to keep certain records, for example, for legal or other reasons); and
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claim compensation for damages caused by a breach of the Data Protection Regulations
If you are not happy with how your personal information is used, I would ask that you contact me, but you have the right to complain to the Information Commissioner’s Office at www.ico.org.uk.
Contacting me
Feel free to get in contact with any questions.