Updated 30.03.2023 v2
5. Roles and responsibilities
7 Distribution and implementation
8 Other Related Procedures and Documents
9 Regulations & Guidance
Protas (which is the trading name of Quality by Randomization Limited, which is a company limited by guarantee with registered number 13073677) respects the privacy of you, our website users and is committed to protecting your personal data.
This policy applies to all users of our website (https://protas.co.uk/).
The website is not intended for children and we do not knowingly collect data relating to children.
5.1 Important information about who we are
5.1.1 Controller and contact details
5.1.3 Third party links on the website
5.2 The data we 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:
- includes your name, title, date of birth and sex/gender.
- includes your postal address, email address, social media handle(s), telephone numbers and correspondence history (including recordings of phone calls with you).
- includes internet protocol (IP) address, browser type and version, time zone setting and location, language preference, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- includes information about your dietary requirements or accessibility requirements when you attend an event;
- includes information about how you use our website.
- includes any personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying you, data concerning health or data concerning your sex life or sexual orientation. You may provide this to us voluntarily, for example as part of a testimonial or using another method of communication with us.
We do not request any information about special category personal data or about criminal allegations, convictions or offences and would ask that you do not provide such information to us.
5.3 How we collect your personal data
We use different methods to collect data from and about you including through:
5.4 How we use 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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. When we talk about our Legitimate Interest, this generally means the interest of Protas in conducting, running and promoting Protas’ work. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
- Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Generally, we do not rely on consent as a legal basis for processing your personal data (where we do rely on consent, we will ask for it before we process the information).
5.4.1 Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To enable you to complete a survey||(a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Special Category Data||Necessary for our legitimate interests – we want to take note of your feedback to ensure the best operation of Protas|
|To promote Protas’s work, for example, (1) where you voluntarily agree to provide us with a testimonial about Protas (2) communicating with you directly (i.e. direct message or private message) on a social media platform if you create a post that relates to Protas||(a) Identify Data (b) Contact Data (c) Profile Data (d) Special Category Data||Necessary for our legitimate interests – improving our website and generating interest in Protas If you voluntarily provide any Special Category Data (e.g. as part of a testimonial) this will be processed based on explicit consent and this will be obtained before we process this data|
|To administer and protect Protas and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data (b) Contact Data (c) Technical Data||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) Necessary to comply with a legal obligation|
|To use data analytics to improve our website, stakeholder relationships and experiences||(a) Technical Data (b) Usage Data||Necessary for our legitimate interests (to keep our website updated and relevant, to develop Protas and to inform our communications strategy)|
Please note that where we have indicated in the table above that our processing of your personal data is necessary for us to comply with a legal obligation and you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our engagement with you.
5.4.3 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.
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.
5.5 Disclosures of your personal data
From time to time we ask third parties to carry out certain business functions for us. These third parties will process your personal data on our behalf (as our processor). We will
disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to other people, we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them. Examples of these third party service providers include service providers and/or sub-contractors, such as our IT systems software and maintenance, back up, and server hosting providers and external legal providers.
In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, in particular:
- If we transfer, purchase, reorganise, merge or sell any part of our business or the business of a third party, and we disclose or transfer your personal data to the prospective seller, buyer or other third party involved in a business transfer, reorganisation or merger arrangement (and their advisors); and
- If we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, Participants or others.
We may also share your personal data with third parties, as directed by you.
In limited circumstances, and only on a voluntary basis with your permission, we may share your testimonial about working with Protas on our website.
5.6 International transfers
If any of our processing activities require your personal data to be transferred outside the European Economic Area, we will only make that transfer if:
- the country to which the personal data is to be transferred ensures an adequate level of protection for personal data;
- we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient;
- the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you; or
- you explicitly consent to the transfer.
5.7 Data security
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.
5.8 How long we retain your personal data for
We keep some types of personal data for longer than others. We will only retain your personal data for a limited period of time. This will depend on a number of factors, including:
- any laws or regulations that we are required to follow;
- whether we are in a legal or other type of dispute with each other or any third party;
- the type of information that we hold about you; and
- whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
5.9 Your data protection rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have certain legal rights, which are briefly summarised in the table below, in relation to any personal data about you which we hold.
Where our processing of your personal data is based on your consent, which should not often be the case in respect of this website or your interactions with us, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.
Where our processing of your personal data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
Should you wish to exercise any of your rights please contact the DPO using the details set out under the Controller heading in the section above.
|Your right||What does it mean?||Limitations and conditions of your right|
|Right of access||Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”).||If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations. We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, e.g. privacy and confidentiality rights of our staff.|
|Right to data portability||Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.||If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations. This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (i.e. not for paper records). It covers only the personal data that has been provided to us by you.|
|Rights in relation to inaccurate personal or incomplete data||You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable. You have a responsibility to help us to keep your personal information accurate and up to date. We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details and telephone number.||This right only applies to your own personal data. When exercising this right, please be as specific as possible.|
|Right to object to or restrict our data processing||Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.||As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes.|
|Right to erasure||Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), e.g. where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.||We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.|
|Right to withdrawal of consent||As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.||If you withdraw your consent, this will only take effect for future processing.|
6. Roles and Responsibilities
7. Distribution and implementation
This document will be made available to all website users on the website at https://protas.co.uk/privacy-policy/.
Quality internal audits will be conducted as part of the ISO9001 Quality Management System and SOPs, and other documents will be reviewed and any non-conformances registered.
8. Other Related Procedures and Documents
9. Regulations & Guidance
- The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations (2019).
- Data Protection Act, (2018)
- The Income and Corporation Taxes (Electronic Communications) Regulation, (2003)
|DPO||Data Protection Officer|