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NABS Privacy Policy

Contents:

1. Introduction

2. Security

3. Data that we hold

  • 3.1 Services

    • 3.1.1 Why do we process data?
    • 3.1.2 What data is processed?
    • 3.1.3 How long do we hold data for?
  • 3.2 Business Contacts

    • 3.2.1 Why do we process Data
    • 3.2.2 What data do we hold?
    • 3.2.3 How long do we hold data for?

4. People who use our website

5. People who use our chatbot service online

  • 5.1 Why do we process NABS chatbot data?

6. Cookies

7. Sharing personal data

8. Locations of processing

9. Individuals rights

10. Complaints

11. Data controller and contact information

12. Changes to our privacy statement


1. Introduction

This policy is designed to ensure that NABS complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

NABS (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, or from a third party acting on behalf of an individual.

Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.


2. Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality, and security.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

All information you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


3. Data that we hold

3.1  NABS Services data

We provide services to individuals as well as organisations. The exact data held will depend on the services to be provided.

Where we engage with individuals, we may collect and process personal data in order to satisfy a contractual or operational obligation. We request that individuals only provide the personal data that is required for us to fulfil our contractual or operational obligation

3.1.1 Why do we process data?

Data is processed in accordance with the purpose for which we have collected it and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of services and activities and the different reasons why we may process your data includes:

  • Personal or professional supportive services – We will process your data if you have expressed an interest or are engaged with NABS for the services we provide. This includes, but is not limited to: Career guidance and support, providing an advice line, one-on-one coaching and counselling and applying for grants on your behalf
  • Partnerships – We will process your data when we work with you as a partner on your behalf, also if you have engaged with NABS as an ambassador for your organisation
  • Research – We may process your data when we conduct research to ensure the services NABS provides are fit for purpose, so we can evolve based on your feedback
  • Events – if you sign up to an event hosted by NABS, or if your name has been provided by a third party or mutual friend of NABS
  • Individual needs. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied and met
  • In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, and maintaining internal operating processes
  • For NABS to do what it does, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include, but is not limited to, the verification of identity of individuals

3.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service. Personal data may include items such as name, contact details and medical records, disability, Next of Kin, ID verification (passport and / or driver’s license), photographs, videos and any other specifically relevant data.

3.1.3 How long do we hold data for?

We retain the personal data processed by us in line with our data retention processes, for as long as is considered necessary for the purpose(s) for which it was collected; there may also be occasions which will require data to be kept for longer, however this will typically be for legal purposes.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it, per our data retention processes. We will periodically review this data, to ensure that it is still relevant and necessary.

Our data retention periods are reviewed periodically to ensure they align with the latest ICO guidelines.

3.2 Business Contacts

Personal data from our contacts, which covers both potential and prior customers is held in our customer relationship management tool (CRM tool).

This information is entered into the system after contact is made between a staff member of NABS and an individual or a business contact individual

3.2.1 Why do we process data?

 

Where personal data on business contacts is held, it is used for several purposes, as follows;

  • Promote and develop our services.
  • Hosting and facilitating of events.
  • To deliver NABS paid-for training.
  • Relationship management.
  • Administration and management.

3.2.2 What data do we hold?

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the meeting or call.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

3.2.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.


4. People who use our website

When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribe to our service, make an enquiry. Where you have previously entered your personal data on our website, we may store this to remember you when you next visit the website and wish to re-enter the data.


5. People who use our Chatbot Service Online

We provide information and signposting to individuals as well as organisations who use the NABS Chatbot. The exact data held will depend on the customer interaction with the chatbot tool.

If you use the NABS chatbot and do not need any further support your data entered will be kept for a maximum period of 30 days and then will be deleted in its entirety from our systems.

If you request further support from NABS, your contact information will be passed to the NABS team and stored on the database in accordance with our standard data processing rules.

NABS can retain your data for the following reasons –

  • To provide service information and signposting to the NABS Advice Line for further support and guidance
  • Research and tracking – to ensure services are fit for purpose
  • Individual feedback to improve content and service improvements

There may also be occasions which will require data to be kept for longer, however this will typically be for legal purposes

5.1 Why do we process NABS Chatbot Data?

Via the NABS Chatbot we process data to be able to provide information and signposting of additional services to you.

Data is processed in accordance with the purpose which we have collected it, and may sometimes be further clarified in written documentation supplied before any data processing may occur.

  • To provide you with service information and signposting to the NABS Advice Line for further support and guidance
  • Research and tracking – We may process your data when we conduct research to ensure the services NABS provides are fit for purpose
  • Individual needs. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services provided to our clients are appropriate

6. Cookies

Like other commercial websites, our Website uses a technology called “cookies” and web server logs to collect information about how our Website is used. A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. For further information on how we process cookies, please see our cookie policy.

We do not process cookies when you are using the NABS Chatbot.


7. Sharing personal data

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

Third party organisations that provide applications/functionality, data processing or IT services to us.

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

  • Venues – We may share your data with venues who host our events for operational and security purposes
  • We may share your data with third parties who deliver professional services on our behalf e.g. counsellor
  • Law enforcement or regulatory agencies or those required by law or regulations
  • Research organisations may receive your personal data, this is so they can provide anonymised statistics for NABS. Your data will be deleted by them, after use

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.


8. Locations of processing

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.


9. Individual’s Rights

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • Individuals may request access to their personal data held by us as a data controller
  • Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered
  • Individuals may request that we erase their personal data
  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us
  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability
  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake

If you wish to exercise any of these rights, please send an email to [email protected]


10. Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to [email protected]

We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website


11. Data Controller and contact information

The data controller for NABS is NABS

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
10 Hills Place
221-223 Oxford Street
LONDON
W1F 7SD

[email protected]


12. Changes to our privacy statement

Updates to this privacy statement will appear on this website. This privacy statement was last updated on 14/06/2021.