JSC Consultant Solutions Ltd. Privacy Notice
Version 3.0, 25/01/2023
Introduction
We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.
We will also explain what rights you have with regards to your personal data and how you can exercise those rights.
Who we are
JSC Consultant Solutions Ltd was founded in 2012. We are a consultancy helping organisations with the design and implementation of management systems such as ISO 27001, ISO 9001, ISAE 3402, SOC1, SSAE 16, SOC2 & ISO 20000.
Our registered office address is:
JSC Consultant Solutions Ltd.
7 Bell Yard
Lower Ground Floor
London
WC2A 2JR
United Kingdom
Collection of personal data
We collect personal data from you for one or more of the following purposes:
- To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
- To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
- To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances it may be your entity, rather than yourself, that has provided us with your personal data.
- To ensure the security and safe operation of our websites and underlying business infrastructure.
- To manage any communication between you and us
The table below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.
In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:
- Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
- Your login information, browser type and version, time zone setting, browser plug-in types and versions.
- Operating system and platform.
- Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through, and from our site.
Lawful basis for the processing of personal data
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.
When we process on the lawful basis of legitimate interest, we apply the following test to determine whether it is appropriate:
The purpose test – is there a legitimate interest behind the processing?
Necessity test – is the processing necessary for that purpose?
Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?
| Purpose of collection | Information category | Data collected | Purpose for collection | Lawful basis for processing | Data shared with? | Retention period |
| 1. To provide you with information | Subject matter information | Name, company name, geographic location, email address, business sector – which may have been captured by your Calling Line Indicator (CLI) data. | To provide appropriate online or email information about products and services that you have requested | Contractual fulfilment | Internally only | Maximum eight years from the date the information is collected. |
| To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest. | Legitimate interest | Internally only | ||||
| Telephone number – which may have been captured by your Calling Line Indicator (CLI) data. | Follow-up to ensure requested information meets needs and identify further requirements. | Legitimate interest | Internally only | |||
| Personal contact information as provided through website forms or at trade shows or any other means. | General mailing list subscription. | Consent | Internally only | |||
| 2. Transactional information | Transaction details | Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery. | To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with. | Contractual performance | Internally only |
Maximum eight years from the date of the performance of the contract. Eight years for VAT records from the performance of the contract |
| For accounting and taxation purposes | Statutory obligation | Internally and professional advisers | ||||
| Documentation should any contractual legal claim arise. | Legitimate Interest | Internally and professional advisers | ||||
| 3. Fulfilment information | Fulfilment data | Name, dietary requirements. | Appropriate catering arrangements for training courses. | Contractual performance | Internally and training venues | Maximum six years from the date of the performance of the contract. |
| Name, contact and identification details. | Access to training courses, attendance registers. | Contractual performance | Internally and training venues | |||
| Name, contact and identification details. | Exam attendance, exam results and certifications. | Contractual performance | Internally and external examiners, proctors and certification bodies | |||
| Name, contact details. | Licensing details necessary for allocation and maintenance of a licence purchased for use of software and related products, distance and e-learning. | Contractual performance | Internally and any third parties whose products or services you may have purchased from us. | |||
| Name, address(es), email address, contact details. | Actual delivery of products or services, in physical or digital form, that you may have purchased from us. | Contractual performance | Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements. | |||
| 4. Security | Security information | Technical information, as described above, plus any other information that may be required for this purpose. | To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts. | Legitimate interest | Internally, forensic and other organisations with which we might contract for this purpose. | Relevant statutes of limitation. |
| 5. Communications | Contact information | Names, contact details, identification details. | To communicate with you about any issue that you raise with us or which follows from an interaction between us. | Legitimate interest | Internally and, as necessary, with professional advisers. | Relevant statutes of limitation. |
| 6. Product development | Survey data | Names, contact details, identification details. | To develop existing and new products that meet the expectations and requirement of our customers. | Consent | Internally and where additional consent is given for marketing purposes. |
If anonymised for statistical research, this data may be kept indefinitely. Where not anonymised, it shall be retained for a maximum of one year. |
Transfer of information outside of the EEA
JSC Consultant Solutions Ltd. is a UK-domiciled organisation whose primary offices are in the UK.
The majority of our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.
From time to time, we may transfer your personal information to our suppliers or service providers based outside of the EEA for the purposes described in this Privacy Notice. If we do this, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, seeEuropean Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use providers based in the US, we will only transfer data to them if they prove they abide by, and process EU Data in compliance with the SCCs (Standard Contractual Clauses) For more informationStandard Contractual Clauses (SCCs).
We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
Your rights as a data subject
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email privacy@jscconsultant.co.uk. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:
The right to be informedAs a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
The right of accessYou may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
a) The purposes of the processing
b) The categories of personal data concerned
c) The recipients to whom the personal data has been disclosed
d) The retention period or envisioned retention period for that personal data
e) When personal data has been collected from a third party, the source of the personal data
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectificationWhen you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten’)Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processingYou may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:
a) The accuracy of the personal data is contested.
b) Processing of the personal data is unlawful.
c) We no longer need the personal data for processing but the personal data is required for part of a legal process.
d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
The right to data portabilityYou may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
The right to objectYou have the right to object to our processing of your data where
- Processing is based on legitimate interest;
- Processing is for the purpose of direct marketing;
- Processing is for the purposes of scientific or historic research; or
- Processing involves automated decision-making and profiling.
Use of Cookies
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Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact us
Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to privacy@jscconsultant.co.uk