Kemp House, 152-160 City Road, London. EC1V 2NX
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This Privacy Notice describes how Fitzgibbon Associates (FA), collects, uses, shares and retains personal information.
This Privacy Notice informs you about the choices you have regarding use, access and correction of your personal information.
FA is committed to ensuring that your personal data is protected and handled in accordance with applicable data protection laws.
For the purposes of this Privacy Notice, references to “we”, “us” or “our” shall refer to FA and the website, www.fitzgibbonassociates.co.uk.
3. About Us
We are a firm of business psychologists providing professional psychological services, (including a range of services designed to promote well-being) to business and private individuals.
Our principal place of business is in London, UK.
Our email address is: firstname.lastname@example.org
Our telephone is: 020 8340 2088
4. What personal information do we hold and process about you?
The personal information we hold includes:
i. Appropriate individual company contacts, and personal contacts (email addresses, telephone numbers and geographical addresses) and other information necessary in the course of doing business.
ii. Psychometric test data, and other relevant information, including detailed personal biographical information, required for the purpose of completing psychological assessments, e.g. assessments for identifying neurodiverse conditions such as dyslexia and dyspraxia.
iii. Notes of, and exercises completed in, coaching sessions.
iv. Relevant information related to assessments or coaching sessions provided to us in emails, email attachments, or mailed to us in hard copy.
We do not record details of financial transactions other than for accounting purposes.
5. The basis on which we process information about you
The law requires us to determine under which of 6 defined basis 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.
6. Legitimate interests assessment for the direct marketing activity we carry out
Purpose. Our legitimate interest behind our direct marketing processing is to provide useful information for organisations regarding the psychological services we provide and to promote our related products and services to those organisations.
Necessity. Processing is necessary for the purposes of the legitimate interests and purpose identified above.
Balancing. With regard to business-to-business marketing the Information Commissioner has stated: "business contacts are more likely to reasonably expect the processing of their personal data in a business context, and the processing is less likely to have a significant impact on them personally". In view of this, in the case of direct marketing and email marketing to business contacts, the legitimate interest is not overridden by the interests of the individual, who as a business person with decision making and budgetary responsibilities can reasonably expect to be contacted with marketing material relating to his or her professional role.
7. Sharing your data
Unless legally obliged to do so, we will not sell or share your Personal Data without your written consent, i.e. we will not sell or give your Personal Data to third parties, including third party advertisers, but when we have your written consent we will if necessary share your personal information with third parties, e.g. your employer, your GP, or your university, who have a legitimate reason for having access to your personal information.
8. How long do we keep your data?
We will retain your personal information for as long as is reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice. The retention period will primarily be determined by relevant legal and regulatory obligation and/or duration of our business relationship with you, your employer or another associated party.
If we are legally able to, we will securely delete or erase your personal information if there is no valid business reason for retaining it or if you request us to delete it.
Records of assessments and coaching sessions are retained for no more than seven years unless there is a legitimate reason, or legal requirement, for us to retain such information for a longer period.
9. How we store your personal data
We take what we believe to be reasonable steps to protect your Personal Data from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free and you should therefore take special care in deciding what information you send to us electronically - please keep this in mind when disclosing any Personal Data to FA.
10. Your rights
You have certain rights as an individual which you can exercise in relation to the information we hold about you. If you make a request to exercise any of your rights, we reserve the right to ask you for a proof of your identity. We aim to acknowledge your request as soon as possible and will attempt to address your query within one week from your request.
Your rights and our obligations are provided in detail at knowyourprivacyrights.org.
In summary you have the following rights:
· Right of access – you have the right to request a copy of the information that we hold about you.
· Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
· Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
· Right of portability – you have the right to have the data we hold about you transferred to another organisation.
· Right to object – you have the right to object to certain types of processing such as direct marketing.
· Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that FA refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, FA can confirm what information it holds about you and how it is processed.
11. Use of our website or professional services by children
We do not provide any of our services to children and our website is not intended for use by children.
In the event that you wish to make a complaint about how your personal data is being processed by FA you have the right to complain to us (you can do so by email: email@example.com. or by telephone: 0208 340 2088) and if you do not get a response within 30 days, you can complain to the ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/