WorkingWin

Privacy Policy

INTRODUCTION  

Welcome to the Working Win privacy policy.

Working Win respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1.  IMPORTANT INFORMATION AND WHO WE ARE  

 PURPOSE OF THIS PRIVACY POLICY  

 This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website.

 This website is not intended for children and we do not knowingly collect data relating to children.

 We take the privacy of your information very seriously. Our Privacy Policy below explains how we will collect and use the information you give us via our website.

We are committed to good information handling principles and protecting the privacy and confidentiality of any personal information we deal with.

When we interact with you, we might give you supplementary privacy notices which are more specific to the personal data we’re collecting or using at that point. You should read those notices alongside this Privacy Policy.

 

CONTROLLER  

Barnsley, Doncaster, Rotherham & Sheffield Combined Authority (BDRS CA) is the controller and responsible for your personal data (collectively referred to as [”BDRS CA”], “we”, “us” or “our” in this privacy policy).

BDRS CA is the controller and responsible for this website.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

 

CONTACT DETAILS  

If you want to request information about our privacy policy or request a copy of any information we hold about you, you can email us using DPO@sypte.co.uk or write to:

The Data Protection Officer

Sheffield City Region

11 Broad Street West

Sheffield

S2 1BQ

The Data Protection Officer is registered with the Information Commissioner’s Office (Reference No: Z5095219).

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

 We keep our privacy policy under regular review. [This version was last updated on [19.16.19]

 

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

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:

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

3.  HOW IS YOUR PERSONAL DATA COLLECTED?  

 We use the following method to collect data from and about you:

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy [LINK] for further details.

 

4.  HOW WE USE YOUR PERSONAL DATA  

Barnsley, Doncaster, Rotherham & Sheffield Combined Authority (BDRS CA) complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We will only use your personal information for the purposes that you would reasonably anticipate or that we state when we collect it and, where necessary, when you have given us your consent. The situations in which this is relevant are set out in the table below.

 

  • Our legal basis for collecting and using your data is Consent.
  • Consent is given when you positively accept the “cookies”. This means your freely given, specific, informed and unambiguous consent which must be collected from you at the time at which it is requested, including in relation to any direct marketing communications.

 

You have the right to withdraw consent. Find out how you can do this, here.

 

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.

Purpose/Activity

Type of data

 

Lawful basis for processing including basis of legitimate interest

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

(a) Usage

(b) Technical

 

Consent to the collection and use of cookies.

 

SHARING YOUR DATA

Your personal data will be treated as strictly confidential, and will be shared only under the following circumstances:

  • Where it is necessary to share with our third party/sub-contracted specialist advisors to help us to promote our services;
  • if we have your consent;
  • in exceptional circumstances – this might be to comply with legal requirement and regulatory requirements, for the administration of justice, to protect vital interests, to protect the security or integrity of our databases or this Site, to take precautions against legal liability;
  • with third parties we are required to partner with to deliver the services you are seeking
  • with regulatory authorities, courts and governmental agencies to comply with legal orders, legal or regulatory requirements and government

 

OPTING OUT  

You have the right to withdraw consent. Find out how you can do this, here.

COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Find out more about Cookies here. For more information about the cookies we use and how we use them, please see our Cookie Policy.

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may share your personal data with the parties set out below for the purposes set out in the table in Section 4.

External Third Parties

Forward and Thinking Ltd

82 York Road

Market Weighton

East Yorkshire

Y043 3EF

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6.  INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area (EEA).

 

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.

 

8.  DATA RETENTION  

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we may rely on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the Data Protection Officer:

The Data Protection Officer

Sheffield City Region

11 Broad Street West

Sheffield

S2 1BQ

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.