Please note that this policy applies only to our website and not to the web sites of other organisations to which we may provide links. We are not responsible for the privacy policies or practices of such third party sites and you should make your own enquiries in respect of them.
Collection of your information
We will collect personal information if you register for our services, or if you make an enquiry. The personal information which you may provide can include your name, mailing address and email address.
We may also collect personal information from you when you access the website for auditing usage of the site and for general administration purposes. The information we may collect will comprise some or all of the following: your name, address, telephone e-mail address, IP address and post code.
We may in some cases collect information about you that may not be personal data. For example, the type of Internet browser you are using, the type of computer operating system you are using, and the domain name of a website from which you linked to our website.
Use of your information
We may use your personal information to identify you as a Client, to process payments, to update our records and to generally manage your visa application or other dealings with us. We will also use the information we collect to track and monitor the usage of our website and help us understand the patterns of site visitors. This will help us operate the site more effectively, identify what sort of information is of interest to our users and assist us in business processes such as accounting, marketing and record keeping.
In addition, we may also use your personal information for the following purposes:
- to help us identify you;
- to enable you to receive the service you have requested; to communicate with you generally;
- research, survey completion and profiling;
- statistical analysis and behavioural analysis;
- to improve the services provided;
- to detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful, including:
- fraud prevention and detection (including credit scoring and credit checking where we have sought your consent);
- for management and auditing of our business operations including accounting
- to comply with legal and regulatory obligations, requirements and guidance
Keeping in touch
We will contact you from time to time with client service announcements on subjects such as new products or services, planned outages affecting the service provided, changes to our terms and conditions or other relevant information.
You will also be able to receive advance pricing change alerts, with a choice of frequency.
We may also contact you in regard to relevant surveys, or in connection with competitions which we may run for Clients.
Retaining your personal information
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- Client’s data will be held for a period of 7 years before being destroyed;
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations; and/or
- Retention periods in line with legal and regulatory requirements or guidance (which will take priority)
We may share your personal information with third parties but only in the strictly limited circumstances set out below:-.
– In certain circumstances we may share your personal information with affiliated companies and service providers who perform functions on our behalf such as our internet service provider. These third parties must at all times provide the same levels of security for your personal information as us and will be bound by a legal agreement to keep your personal information private and secure.
– We may also supply your personal information to government bodies and law enforcement agencies but only: if we are required to do so by the requirements of any applicable law; if in our good faith judgment, such action is reasonably necessary to comply with legal process; to respond to any claims or actions; or to protect our rights or those of our customers and the public.
We are committed to protecting the privacy of your personal data. We use appropriate standards of technology and operational security to protect personal information including a secure server and network firewall connection. Operationally, access to personal information is restricted to authorised personnel who are under a duty to maintain the confidentiality and security of such information.
The Internet is inherently insecure. Personal information submitted by means of the Internet may be vulnerable to unauthorised access by third parties. Submission of personal information using the Internet is at your own risk. We will take reasonable and appropriate technical measures to ensure that your personal information is stored in a secure manner. However, we shall have no liability for disclosure of data due to errors in transmission or the fraudulent, negligent or other illegal acts of a third party, such as ‘Hacking’. Any transmission of personal information on or through the use of our website is at your own risk
Transmission of Data Overseas
In certain circumstances, we may transfer your personal information to countries outside the European Economic Area. This may include circumstances where we use service providers who are based outside the EEA or who use “cloud” infrastructure which means that their servers are based all over the world. Where we transfer your information to companies outside the EEA, we will make sure it’s protected in a manner that is consistent with how your information will be protected by us. This can be done in a number of different ways for instance:
- The country that we send the information to might be approved by the European Commission.
- The recipient company might have signed a contract obliging them to protect your information.
- The recipient is located in the US and is a certified member of the EU-US Privacy Shield scheme.
In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases however, we will ensure that any transfer of your information is compliant with the Data Protection Legislation.
You have a number of legal rights in relation to the information that we hold about you, including:
- Right to access: You have the right to request access to your personal data held by us. Requests are to be made in writing, electronically and information will be provided in a commonly used electronic format. Requests will be handled within one month of receipt of the request, and free of charge with the exception of where requests are manifestly unfounded or excessive we hold the right to charge a reasonable fee taking into account the administrative costs of providing the information. More information can be found at https://ico.org.uk/for-the-public/personal-information/.
- Right to rectification: You have the right to have personal data rectified if inaccurate or incomplete. Where the personal data in question has been disclosed to a third party, they will be made aware of the rectification where possible. Requests are to be made in writing, electronically, and will be handled within one month of receipt of the request.
- Right to erasure: You have the right to request the deletion or removal of personal data in the following circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- When you withdraw consent.
- When you object to the processing and there is no overriding legitimate interest for continuing the processing.
- The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
- The personal data has to be erased in order to comply with a legal obligation.
This does not provide an absolute “Right to be forgotten”. Where the personal data in question has been disclosed to a third party, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. Personal data will be erased by removal from our internal and cloud servers.
- Right to restrict processing: You have a right to ‘block’ or suppress processing of personal data if you contest its accuracy; have objected to the processing; processing is unlawful and you oppose erasure; we no longer need the personal data but you require the data to establish, exercise or defend a legal claim. Where the personal data in question has been disclosed to a third party, we will inform them about the restriction on processing of the data, unless it is impossible or involves disproportionate effort to do so.
- Right to data portability: You have the right to obtain and reuse your personal data for your own purposes. Requests are to be made in writing, electronically, and will be handled within one month of receipt of the request.
- Right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. Requests will be dealt with by immediate effect with no right for refusal.
You also have the right to make a complaint with the Information Commissioner at www.ico.org.uk if you think that any of your rights have been infringed by us.
All requests will be dealt with in your own merit, and in accordance with the Data Protection Legislation guidance.
Should a data breach occur, we have compliant procedures in place to investigate and report the matter to the Individual. In the event of a breach, it will be reported to you within 72 hours of discovery. A record of any breaches will be kept by the company.
You can exercise your rights by contacting us using the details set out in the “Contact Address” section below.
Ian Harrop & Associates
19A Graham Street
Edinburgh EH6 5QN