GENERAL PRIVACY NOTICE
Your personal data – what is it?
“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or physical address). Identification can be directly using the data itself or by combining it with other information which helps to identify a living individual (e.g. a list of staff may contain personal ID numbers rather than names but if you use a separate list of the ID numbers which give the corresponding names to identify the staff in the first list then the first list will also be treated as personal data). The processing of personal data is governed by legislation relating to personal data which applies in the European Union including the General Data Protection Regulation (the GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.
Who are we?
This Privacy Notice is provided to you by Knogin Ltd. which is the data processor for your data.
Other data processors we work with:
- Hubspot (our CRM Suite)
- Atlassian (our Trouble Ticket management system)
- Google (Gsuite – our email system)
- Protonmail (our secure email system for encrypted communications)
We may need to share your personal data we hold with them so that they can carry out their responsibilities to us. If we and the other data processors listed above are processing your data jointly for the same purposes, then Knogin Ltd. and the other data processors may be “joint data processors” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data processor.
A description of what personal data Knogin Ltd. processes and for what purposes is set out in this Privacy Notice.
Knogin Ltd. will process some or all of the following personal data where necessary to perform its tasks:
- Names, titles, and aliases;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where they are relevant to us (such as when a person applies for employment), or where you provide them to us, we may process information such as gender, age, marital status, nationality, education/work history, academic/professional qualifications, hobbies, family composition, and dependants;
- Where you pay for services, financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers, and claim numbers;
- The personal data we process may include sensitive or other special categories of personal data such as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning and sexual life or orientation.
- System event logs and electronic behavioral patterns
How we use sensitive personal data
- In circumstances where you send us log data, this data may allow us to identify personally sensitive things such as behaviors, mistakes or criminal activity through web browsing data, connectivity, actions on a device and such. Your web browsing habits, for instance, may reveal sensitive information such as your ethnicity, sexual orientation, membership of a worker’s union, religious beliefs and marital status.
- These types of data are described in the GDPR as “Special categories of data” and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
- We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest.
- In order to defend our clients from potentially harmful events
- Less commonly, we may process this type of personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent to process your sensitive personal data?
- In limited circumstances, we may approach you for your written consent to allow us to process certain sensitive personal data. If we do so, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
- Ordinarily, the data controller (e.g. your employer) is responsible for obtaining your consent for using your data and are required to ensure that you opt in to having your data processed by Knogin Ltd.
Knogin Ltd. will comply with data protection law. This says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data from loss, misuse, unauthorised access and disclosure.
We use your personal data for some or all of the following purposes:
- To deliver services including to understand your needs to provide the services that you request and to understand what we can do for you and inform you of other relevant services;
- To confirm your identity to provide some services;
- To contact you by post, email, telephone or using social media (e.g., Facebook, Twitter, WhatsApp);
- To help us to build up a picture of how we are performing;
- To detect fraud and cyber-attacks and where necessary to assist law enforcement functions;
- To enable us to meet all legal and statutory obligations and powers including any delegated functions;
- To carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice from time to time with the aim of ensuring that all children and adults-at-risk are provided with safe environments and generally as necessary to protect our clients and their businesses or families from harm;
- To promote the interests of Knogin Ltd. and / or Knogin Inc. and / or subsidiaries;
- To maintain our own accounts and records;
- To seek your views, opinions or comments;
- To notify you of changes to our facilities, services, systems, events and staff;
- To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other new projects or initiatives;
- To process relevant financial transactions including payments for goods and services supplied to or by Knogin Ltd.
- To allow the statistical analysis of data so we can plan the provision of services.
Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
What is the legal basis for processing your personal data?
Knogin Ltd. is a private company and has certain legal obligations. Most of your personal data is processed for compliance with a legal obligation which includes the discharge of Knogin Ltd.’s duties. Sometimes when exercising these duties, it is necessary to process personal data of clients or people using Knogin Ltd.’s services. We will always take into account your interests and rights. This Privacy Notice sets out your rights and Knogin Ltd.’s obligations to you.
We may process personal data if it is necessary for the performance of a contract with a client (the Data Controller), or to take steps to enter into a contract. An example of this would be processing your data in connection with the use of a client’s enterprise resources, such as networks, computers, etc.
Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use in those cases.
Sharing your personal data
This section provides information about the third parties with whom Knogin Ltd. may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- The data processors listed above under the heading “Other data processors we work with”;
- Our agents, suppliers and contractors. For example, we may ask a commercial provider to publish or distribute newsletters on our behalf, or to maintain our “potential client list”;
- On occasion, other organisations with which we are carrying out joint ventures e.g. in relation to conferences.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is currently best practice to keep financial records for a minimum period of 8 years to support financial audits or provide tax information. We may have legal obligations to retain some data in connection with our obligations to local governments in the location where your contract is defined. Knogin Ltd. is permitted to retain data in order to defend or pursue claims. In some cases, the law imposes a time limit for such claims (for example 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases, we will need you to respond with proof of your identity before you can exercise these rights.
The right to access personal data we hold on you
- At any point, you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee
The right to correct and update the personal data we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
The right to have your personal data erased
- If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
- When we receive your request, we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).
The right to object to the processing of your personal data or to restrict it to certain purposes only
- You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
- You can withdraw your consent easily by telephone, email, or by mail (see Contact Details below).
The right to lodge a complaint with the Information Commissioner’s Office.
- You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Transfer of Data Abroad
If you are an EU Citizen living in the EU, any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on this web page. This Notice was last updated in October, 2018.
Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:
The Data processor, Knogin Ltd. International House, 776-778 Barking Road, London, E13 9PJ, United Kingdom
Phone: +44 20 3000 6837