This is the privacy notice of The Kensey Centre. In this document, “we”, “our”, or “us” refer to The Kensey Centre.
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
1 – Data Protection Officer
Each of our practitioners is an individual DPO, they have responsibility for ensuring the policy is followed.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact your practitioner.
2 – Data we process
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information includes information such as address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Technical data includes your 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.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate profile data to assess interest in a product or service.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
3 – Special personal information
Special personal information is data 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.
We may collect special personal information about you if there is a lawful basis on which to do so.
4 – If you do not provide personal information we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
5 – The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.
If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
5 – Information we process because we have a contractual obligation with you
When you purchase a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to provide you with our services.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
6 – Information we process with your consent
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
7 – Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
- For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of The Kensey Centre
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- protecting your interests where we believe we have a duty to do so
8 – Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
9 – Complaints regarding content on our website
We do not permit user generated content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
10 – Communicating with us
When you contact us, whether by telephone or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
11 – Complaining
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
12 – Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner. The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy. Use of information we collect through automated systems when you visit our website.
13 – Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
14 – Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you.
Disclosure and sharing of your information
15 – Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
Control over your own information
16 – Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
17 – Access to your personal information
To obtain a copy of any information you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information.
18 – Removal of your information
If you wish us to remove personally identifiable information from our records, you should contact us to make your request.
This may limit the service we can provide to you.
19 – Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
20 – How you can complain
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
21 – Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
22 – Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website or services.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.