The Old Library,
This policy (and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand how your personal data will be processed.
RWA Compliance Services Ltd. acts in the capacity of the data controller and data processor and will treat all your personal information as private and confidential, in accordance with the Data Protection Act 1998 and subsequent legislation.
Our contact details for data protection purposes are:
RWA Compliance Services Ltd, Lion Street, Blaenavon. Torfaen. NP4 9QA
Tel: 01604 709 509 | E-mail: firstname.lastname@example.org
Information we collect:
1: Website visitors
The law about cookies changed in May 2011. Websites must get your agreement before they set certain types of cookie on your computer or handheld device.
2: Email newsletter sign-ups
RWA invites Trade & Export Online newsletter signups in person, via email, via websites, or via the Insight blog. Those submitting their personal details (name, job title, phone number, email address) will be added to a CRM database (provided by Capsule) and sent weekly emails (via MailChimp or Campaign Monitor) regarding regulatory and relevant professional topics. Open rates and interactions with emails are recorded for analytical purposes.
RWA records details (name, job title, phone number, email address) of clients and those working for clients, on a central CRM database (Capsule CRM), along with details of any correspondence between the client and RWA.
RWA maintains a record of prospect organisations. Where affirmative opt-in consent has been obtained, RWA also maintains a record (on Capsule CRM) of individuals (name, job title, phone number, email address) working at prospect organisations, including any correspondence between the prospect organisation and RWA.
5: e-Learning platforms
RWA operates e-Learning platforms (The Aviva Development Zone, My Development Zone, Trade and Export Online), via which we collect IP addresses, usage data (via RWA and Google Analytics cookies), names, email addresses, and payment details of e-learners.
Why does RWA collect this information?
RWA collects the above information for the following purposes:
1. To continually monitor and improve the performance of RWA websites
2. To manage and service email newsletter lists. RWA will monitor email engagement and maintain a permission-based database. Data will be retained for a minimum of seven years.
3. To service client accounts and fulfil client contracts, including maintaining a record of correspondence. In line with professional practices, details of correspondence will be recorded for a minimum of seven years.
4. To manage the dialogue between RWA and prospect accounts. RWA will seek to continually refresh consent with prospects wherever possible.
5. To manage e-Learning platforms and individual accounts, to record platform usage, and continually develop the functionality our e-Learning solutions. Data will be retained for a minimum of seven years.
RWA practices a policy of data minimisation. We will only record essential data and will minimise and securely dispose of any data, which is no longer required.
In the interests of security and to improve our service, telephone calls may be monitored and/or recorded.
Lawful basis and consent
For data subjects who have a contract with RWA or are taking steps to enter into a contract (for one or more of the following: Compliance / Solutions / HR / e-Learning / Training / Broker Match), our lawful basis for processing individuals’ data is:
6(1)(b) – Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
RWA takes no responsibility for our client's HR policy statements. Personal data for clients’ employees supplied to RWA shall be processed under the above lawful basis.
RWA will rely upon consent to process the personal information for any individual with whom we do not have a contractual obligation.
For past / lapsed clients, our lawful basis is:
6(1)(f) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
RWA also operates permission-based marketing databases. Our lawful basis for this data is:
6(1)(a) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
What will RWA do with personal data
RWA may use information held about you to (i) provide you with information about other similar products and services which we can provide and which we feel may be appropriate to you, by email, telephone, post or other means. You will be asked to provide consent to each separate communication method when submitting your personal data. (ii) RWA may transfer your personal data to other RWA Group companies and external companies directly connected to the fulfilment of RWA products and services, to provide you with other similar products and services; (iii) the following third parties acting on our behalf, including:
1. Troubleshooters Accountancy, Blaenavon
2. Delivery partners
3. Capsule CRM
4. Mailchimp and/or Campaign Monitor
RWA will not directly transfer any data that we hold about you outside of the European Economic Area member countries which apply the same level of protection to data held there as in the United Kingdom.
Where RWA does use third parties outside of the EU to process data relating to EU citizens, it will ensure that suitable contracts, policies, procedures and recognised data protection standards or codes of conduct are in place to protect personal data.
Your individual rights
Should you not wish us to use or process your data in this way, we may not be able to arrange or administer your contract[s] with RWA or process data as necessary for the performance of a contract in order to meet our contractual obligations to you.
Email is not a completely secure means of transmission of data or documents, so by providing your email address to us, you are giving your informed consent to us using this method to contact you and to send you your documents. If you would prefer us not to use this method of contact, please contact us.
Provision of personal data is obligatory for us to meet contractual obligations to you and will be held until you request it is removed.
At contract renewal, we shall assume the personal data we hold about you is correct. If this is not the case and the data has changed in any way, please let us know.
You have the following rights: request access to data relating to you, the rectification or erasure of data held about you (subject to other conditions), the right to request copies of your data held by us and the right to object to our use of your data.
If you believe that any information we are holding about you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect. You also have the right to complain to the Supervisory Authority, this is the Information Commissions Office (ICO) (www.ico.org.uk) about our data processing activities.
You may exercise your right to give notice to stop data being processed for any purpose by contacting us at any time. In the first instance, please email email@example.com. To unsubscribe from emails, please use the unsubscribe link at the bottom of each email.
Except as set out in this document, we will not otherwise disclose any information to any other parties without your written consent, unless we are legally obliged to do so.
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