General Privacy Notice
Blackford Analysis Ltd (Blackford) is committed to ensuring that your privacy is protected. This policy sets out the basis on which your personal data will be processed by us. You can be assured that your personal data will only be used in accordance with this policy and applicable regulations, including the EU General Data Protection Regulation (GDPR) 2016/679, UK General Data Protection Regulation and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”), upon the effect of the United Kingdom leaving the European Union.
What we collect
We may collect the following data about you:
- Information about you that you give us by filling in details on our website www.blackfordanalysis.com or by corresponding with us by phone, e-mail, LinkedIn, social media, completing surveys, in person during onsite visits, meetings and, at tradeshows and events or otherwise. The information you give us may include your name, address, e-mail address, phone number and other relevant information. If you are a customer or a potential customer of Blackford you may refer to MSRef-107 for further details regarding the data we collect for doing business with you.
- Technical information regarding your visits to our Website including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
- Information that you provide when using the Blackford Products: The Navigator Tool and The Dashboard. For Blackford Dashboard users, we collect information related to your user account, this includes email, first name, last name, language locale.
- For Recruitment Purposes, for further details regarding data collected for recruitment please refer to MSRef-106.
What we do with the information we gather
Your personal data will only be retained and processed by Blackford when we have a lawful basis on which to do so to meet a legal obligation, in association with a contract, where we have a legitimate interest or with your consent for a particular purpose.
We require this information in order to conduct business with you, to understand your needs or to provide you with a better service and, in particular:
- For internal record keeping.
- For recruitment purposes.
- To periodically send promotional emails, newsletters or other information which we think you may find interesting.
- Occasionally, to contact you by email for market research purposes.
How long do we keep your personal data?
Data and documentation is retained in alignment with legal, financial, regulatory and contractual requirements. We maintain a record retention schedule to define the retention life for each type of data.
How we use cookies and IP addresses
We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and Website quality improvements. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
Our Website uses cookies to distinguish and identify you from other users of our Website. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a more personalized service when you browse our Website and also allows us to improve our Website. For Blackford Dashboard users, cookies allow us to remember a session (i.e. remembers you are logged in) and remember viewing preferences you have set.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Website.
How we share your Personal Information
We will not share any of your Personal Data with any third parties for any purposes, subject to the following exceptions:
- If we sell, transfer, or merge parts of our business or assets, your Personal Data may be transferred to a third party. Any new owner of our business may continue to use your Personal Data in the same way(s) that we have used it, as specified in this Privacy Policy.
- In some limited circumstances we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Data Protection and Information Security
We are committed to ensuring that your information is secure. In order, to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we retain. The Information Management System at Blackford is certified to ISO 27001.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- When you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by for direct marketing purposes, and
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at the email address below.
Your rights
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Rectification
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us.
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organization. The above right exists only in respect of personal information that:
- You have provided to us previously; and
- Is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.
Consent
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by using the details in the Contact section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
Complaints
If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods.
Telephone 0303 123 1111
Website https://ico.org.uk/concerns/
Post Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Blackford is registered with the Information Commissioner as a data controller, with registration number Z3297738.
If you live or work outside the UK or have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.
EU Representative
We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy matters, please email our Representative at eurep@itgovernance.eu Please ensure to include our company name in any correspondence you send to our Representative.
IT Governance Europe Limited. The Mill, Newtown Link Rd, Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland.
Changes to our Privacy Policy
This privacy policy can be changed by Blackford at any time. If we change our privacy policy in the future, we will advise you of material changes or updates to our privacy policy by email.
Further Information
If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact Us
Blackford Analysis Ltd.
160 Causewayside
Edinburgh
EH9 1PR
UK
Data Protection Lead: Evie Eccles, VP QARC Email: QARC@blackfordanalysis.com