TAG take your privacy seriously. This policy embraces the collection, processing and other use of personal data under the Data Protection Act 1998 (DPA) and also the General Data Protection Regulations (GDPR).
For DPA and GDPR purposes TAG are the data controller and any enquiry regarding the collection or processing of your data should be made to Robert Russell at the following:
Address: Longcroft House, 2 – 8 Victoria Avenue, London, EC2M 4NS
Tel: 020 7175 7275
Email: Email TAG
This notice explains how TAG protects your information, including the data that is collated when you use our website and our services.
This policy will be updated from time to time in line with the General Data Protection Regulations (GDPR) or current legislation.
2. LAWFUL BASIS FOR PROCESSING INFORMATION
In order to carry out and perform its role as a personal development organisation, TAG needs to collect and use certain types of information about people applying for training, therapy or personal development who are existing or past clients, as well as members of the public who visit its website or who wish to obtain information of apply for TAG’s services. TAG deem that our lawful basis for processing information is one of legitimate interest, since without the collection and the retaining of your information we are unable to provide the necessary services required by our visitors or clients.
TAG is dedicated to the lawful and correct handling of personal information in line with the General Data Protection Regulations and has taken all reasonable precautions with regard to storing and processing of your information to ensure that it is protected.
The Data Controllers are:
The TAG Administrators
The Data Processors are:
The TAG Administrators
From time to time we will contract with external agencies to provide services on our behalf. In all instances we will seek written assurance that these agencies are compliant with the GDPR principles.
3. GDPR PRINCIPLES
TAG will ensure personal data is:
Ø Processed lawfully, fairly and in a manner transparent in relation to the data subject
Ø Collected for legitimate, specified and explicit purposes that is not further processed for additional purposes incompatible with those purposes
Ø Processed in a way that ensures appropriate security of the personal data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
Ø Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed
Ø Relevant, adequate and limited to what is necessary in relation to the purposes for which data is processed
Ø Accurate and, where necessary, kept up to date
4. USE OF YOUR INFORMATION
TAG may use personal information provided by members and those seeking membership for the necessary purpose of providing our services or matching site visitors with requested member information. We will also supply any information given by members of the public who wish to communicate with representatives of TAG.
Information gathered by TAG may also be used for the following purposes:
Ø To consider and decide upon eligibility for courses, therapy or personal development services
Ø To enable the general public to search our website to check TAG representatives’ statuses and to make contact with those representatives
Ø To administer, update and maintain any Directory of TAG therapists and maintain the database, which includes all levels of association
Ø To process and respond to requests, enquiries and complaints received from the public, representatives of TAG and therapists within the TAG directory
Ø To communicate with clients, students and site visitors about our services, news and events
Ø To communicate with clients, students and site visitors regarding TAG benefits – eg any general collective or individual communications and the provision of certificates
Ø To compile statistics through the analysis of profiles and trends
Ø To ensure any client or student supervision is tailored to individual needs
Ø To liaise with clients or students supervisors, with consent from the relevant client or student, concerning any areas of development identified following any development work with TAG
Ø To survey those wishing to take up TAG services
Ø To prevent or detect fraud
Ø For audit purposes
TAG does not store bank or card details except for the purposes of processing refunds that you have requested us to make and such data will be deleted immediately after our part has been actioned.
TAG will hold clients’ and interested parties’ personal information on our systems for any necessary duration to comply with company law requirements, and thereafter for a period of 7 years after the last contact with every client and interested party.
After this time, in compliance with Article 5 of the GDPR, TAG will delete clients’ and interested parties’’ records in a secure manner unless there has been a complaint about any client or interested party.
All historic data pertaining to TAG Administrative decisions and actions will be stored for the duration of the existence of Training Alliance Group in compliance with company law requirements.
5. COLLECTING PERSONAL INFORMATION
The details of any criminal convictions disclosed to TAG will also be held for the duration of a decision making process. If we conclude the conviction does not impede a client or interested party from maintaining their association with TAG, we will delete all reference to this. Should we decide it does mean a client or interested party can no longer maintain their association with TAG, that client or interested party will be informed of this by us. Thereafter we will remove the relevant client or interested party information from public view. However in such an instance, a past client or interested party’s data will continue to be retained for one year.
TAG will process personal information from all new clients or interested parties to perform its function. If a client or interested party is not content to allow us to process their personal information, that client or interested party will not be eligible for any association with TAG.
6. TAG REPRESENTATIVE INFORMATION THAT WILL BE VISIBLE TO THE PUBLIC
Certain information TAG representatives provide to TAG will be made visible by us to anyone visiting our website and/or enquiring about any representative. The public can inspect the following information on the online register:
Ø Full name of TAG representative
Ø Registered discipline and qualifications of a TAG representative
Ø The practice address and post code provide to us by a TAG representative
NB This information can be details of your practice premises or, if you do not have a separate practice address, details of your home address
Ø The practice address, including Town/City/County/Country provided to us by a member
Ø The practice telephone number(s) provided to us by a TAG representative
Ø The appropriate practice website address(es) provided to us by a TAG representative
Ø A TAG representative’s TAG registration number
Ø Any photograph or logo provided to us by a TAG representative
Ø Professional details provided to us by a TAG representative for TAG profile purposes
A TAG representative’s home address details (unless the same as the practice address), date of birth and other data are not available to the public unless given by a TAG representative to TAG specifically for that purpose.
7. INFORMATION FROM A WEBSITE ENQUIRER THAT WILL BE VISIBLE TO A MEMBER
Any information supplied by a member of the public or client enquiring about the services of a TAG representative, whether through filling in an online form or providing details over the phone for such purposes, will be held by TAG for one year only. It will also passed as soon as practicably possible to any or all TAG representatives deemed professionally suitable to fulfil the therapy, study or personal development requirements of that member of public.
Public Enquiry Information passed on will be limited to:
Ø The enquirer’s name
Ø The contact details provided by the enquirer
Ø The personal details provided by the enquirer relevant to the therapy, study or personal development sought
8. SOCIAL AND BUSINESS MEDIA
TAG operate social media accounts. TAG representatives deciding to participate with these accounts and their associated posts must appreciate and accept that participation will be visible to the public.
9. LINKS AND LINKING TO OTHER WEBSITES
10. CONTACT WITH YOU FROM TAG
The purposes and nature of the relationship between TAG and its clients’ and interested parties’ mean you can be contacted through any of the following mediums: telephone, email or letter. If a client or interested party prefers not to be contacted through one or some of these mediums, this can be made clear by updating your preferences through being given the opportunity to unsubscribe to emails or other contact mediums at any time.
TAG will contact members of the public enquiring about TAG services via the preferred and selected contact method provided at the time the enquiry is made. At any time during the communication process between an enquiring member of the public and either TAG, or a representative of TAG, the enquirer can elect and request that all further communication to be immediately ceased.
12. SECURITY AND PERSONAL DATA STORAGE
TAG take all reasonable steps to hold information securely in electronic or physical form and to prevent unauthorised access, modification or disclosure. Our information security policy is supported by a number of security standards, processes and procedures and information is stored in access-controlled premises or in electronic databases requiring logins and passwords.
All TAG Administrators with access to confidential information are subject to confidentiality obligations.
13. SHARING OF INFORMATION
TAG will not disclose your information with anyone without your written consent unless required to do so under a legal, regulatory or professional obligation except with your express written permission
14. YOUR RIGHTS
You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data. If you are based within the UK or the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will also have the following rights:
Ø To ask TAG to provide you with information regarding the Personal Data we process concerning you
Ø To rectify, update or complement inaccurate or incomplete Personal Data concerning you
Ø To delete or request the erasure of Personal Data concerning you
Ø In certain circumstances to restrict the way in which TAG processes Personal Data concerning you
Ø To withdraw any consent you may have given TAG to process Personal Data concerning you
Ø To object to TAG processing Personal Data concerning you
Ø To obtain from TAG the portability of Personal Data concerning you which we process using automated means on the basis of your consent or of a contract you have entered into with TAG; and
Ø In the European Economic Area, to lodge a privacy complaint with a supervisory authority if you are unhappy with the way TAG has handled your Personal Data or any privacy query or request that you have raised with us
Where your exercise of any of the rights above is dependent on TAG’s actions, we will abide by the legal obligation to take reasonable measures to ascertain your identity and the legitimacy of your request, and may ask you to disclose to us any information necessary for that purpose.
TAG will respond to a legitimate request within 30 days, although in certain limited circumstances, we may need to extend our response period as permitted by law.
Please also note that some of the rights above may not be applicable to you (or to all of the information about you that TAG is processing) due to the application of one or more of the Exemptions set out below
If you consider TAG’s use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: http://www.ico.org.uk/
Article 14 of the GDPR states that it is not necessary to supply information about the data TAG process where that information has not been received from the individual concerned and “where the personal data concerned must remain confidential subject to an obligation of professional secrecy regulated by [English] law”.
In addition, Schedule 2 of the Data Protection Act 2018 exempts us from providing information about:
Disclosures of personal data to us or by us where the disclosure is:
Ø Required by an enactment, a rule of law, or an order of a court
Ø Necessary for the purpose of, or in connection with, legal proceedings (including prospective legal proceedings)
Ø Necessary for the purpose of obtaining legal advice or otherwise establishing, exercising or defending legal rights
Ø Processing of personal data that consists of information in respect of which a claim to legal professional privilege could be maintained in legal proceedings
14. IF YOU DO NOT WANT TO RECEIVE MARKETING INFORMATION FROM TAG
15. AUTOMATIC DECISION MAKING
TAG do not make decisions based solely on automated data processing, including profiling.
16. STATUS OF THIS POLICY
17. CONTACT AND FURTHER INFORMATION
Last updated: January 2019