- We are committed to safeguarding the privacy of my constituents.
- This policy applies where we are acting as a data controller with respect to the personal data of constituents; in other words, where I and my staff determine the purposes and means of the processing of that personal data.
- My website incorporates privacy controls on each form which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct communications from me and limit the collection, sharing and publication of your personal data.
- In this policy, “we”, “us” and “our” refer to Sarah Jones and associated office staff.
The personal data that we collect
- In this Section 2 we have set out the general categories of personal data that we process.
- We may process data enabling us to get in touch with you (“contact data”).[ The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers which you choose to share with us.
- We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website.
- We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and our payment services provider Stripe.
- We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website forms.
- We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, broad geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.
- We may process data you provide to us such as your name, residence, postcode, and details of your query in the course of our work on your behalf.
Purposes of processing and legal bases
- In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
- Operations – We may process your personal data for provision of our services to you. The legal basis for this processing is our legitimate interests, namely representing your interests in parliament, advising you, assisting you with public services, or making an appointment for you with us or another service provider.
- Publications – We do not publish your information.
- Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is legitimate interests, namely representing your interests in parliament, advising you, assisting you with public services, or making an appointment for you with us or another service provider.
- Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is your consent provided when you opt-in to such communications.
- Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with us. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website and the services it provides to constituents.
- Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our communication records. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently serve you in accordance with this policy.
- Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
- Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our office, website, and staff against risks.
- Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
- Your personal data held in our website database will be stored on the servers of our hosting services providers worldstream.net.
- We may disclose personal data to our suppliers or subcontractors for legitimate purposes such as running our office case management system.
- Financial transactions relating to our website are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at stripe.com.
- In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
- In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law or EU data protection law.
- We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
- The hosting facilities for our website are situated in The Netherlands and the United Kingdom. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from https://ico.org.uk/
- You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
- This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- We will retain your personal data as follows:
- Contact data will be retained for a minimum period of 90 days following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
- Transaction data will be retained for a minimum period of 90 days following the date of the transaction, and for a maximum period of 10 years following that date;
- Communication data will be retained for a minimum period of 90 days following the date of the communication in question, and for a maximum period of 10 years following that date]; and
- Usage data will be retained for 90 days following the date of collection and for a maximum period of 10 years;
- Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- In this Section 7, we have listed the rights that you have under data protection law.
- Your principal rights under data protection law are:
- the right to access – you can ask for copies of your personal data;
- the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure – you can ask us to erase your personal data;
- the right to restrict processing – you can ask us to restrict the processing of your personal data;
- the right to object to processing – you can object to the processing of your personal data;
- the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
- the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
- These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
- You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out on the contact page of this website.
- 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.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies used by our service providers
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of changes to this policy by email.
- This website is owned and operated by Sarah Jones.
- Our principal place of business is at 43 Blackhorse Lane, Croydon CR0 6NL.
- You can contact us:
- by post, to 43 Blackhorse Lane, Croydon CR0 6NL;
- using our website contact form;
- by telephone, on the contact number published on our website; or
- by email, using the email address published on our website.
- Our representative within the EU and the UK and data protection officer with respect to our obligations under data protection law is our office manager and you can contact our representative using the information on the contact page.