UKHab Ltd registered address is: 1 Maple Road, Bramhall, Stockport, Cheshire SK7 2DH

Any queries about your information or these policies, please contact our Data Manager at contact@ukhab.org

DATA PROTECTION POLICY AND IT SECURITY

UKHab Ltd is committed to maintaining the privacy of all individuals (including any identified or identifiable natural person) with whom we interact during the course of our business. At all times UKHab Ltd will comply with relevant Data Protection legislation, including the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and theGeneral Data Protection Regulations 2018.

This policy aims to provide a range of security defences against the threats detailed below and also to ensure that UKHab Ltd is compliant with the current legislation including the Computer Misuse Act 1990.

IT SECURITY

The security and confidentiality of IT systems, and the data within those systems, are of considerable importance.

Protection of Hardware from Theft or Accidental Damage

• All directors and staff must keep IT equipment secure at all times.
• All IT equipment which is owned by UKHab will be security marked
• UKHab Ltd. cannot be held responsible for the loss or damage of personal property.
• When a laptop is used at conferences and events all reasonable security arrangements should be taken.
• Electronic files stored on USBs or hard copy files should not be left unattended if these contain confidential or sensitive information
• Documents stored on portable electronic equipment such as laptops or USBs should be adequately encrypt

Protection of Data from Hardware Loss

• Regular backups of UKHab Ltd data will be taken and stored appropriately
• Firewalls and antivirus software will be subject to regular update

Protection of Data from Unauthorised Access

• All UKHab Ltd directors will have an email signature on all correspondence sent.
• The Data Manager (or similar such role covering this task) will keep a list of authorized persons and remove any rights to data systems on notification of a change of authorisation.
• Passwords and Usernames are kept secure and only shared with other Organisation staff when required
• Passwords and logins for the financial systems and banking should not be shared with anyone. Individuals should use their own login and card authorisation readers at all times.

Breaches of security

• All actual and potential breaches of security should be reported immediately to the Data Manager

Prohibited activities

The following activities are considered unacceptable by anyone working for or on behalf of UKHab Ltd:

• Distributing, disseminating or storing images, text or materials that might be considered illegal, discriminatory or abusive
• accessing copyrighted information in a way that violates the copyright
• breaking into the company’s or another organisation’s system or unauthorised use of a password/mailbox

GENERAL DATA PROTECTION REGULATIONS

All UKHab Ltd Directors, contractors or anyone working for or on behalf of UKHab Ltd are responsible for compliance and ensuring that personal information maintained by the Organisation is not disclosed orally or in writing or accidentally or otherwise to any unauthorised third party. Any deliberate breach of this policy may lead to disciplinary action being taken against them. The General Data Protection Regulations 2018 (GDPR) set out procedures which are to be followed when dealing with personal data.

These procedures are to be followed by UKHab Ltd, consultants, partners and any other parties working on behalf of UKHab Ltd. UKHab Ltd views the correct and lawful handling of personal data as the key to its success and dealings with third parties. UKHab Ltd shall ensure that it handles all personal data correctly and lawfully.

Our data protection principles

All personal data:

• Must be processed fairly and lawfully
• Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes
• Must be adequate, relevant and not excessive in relation to the purposes for which it is processed
• Must be accurate and, where necessary, kept up-to-date
• Must be kept for no longer than is necessary for the purpose(s) for which it is obtained
• Must be processed in accordance with the rights of data subjects
• Must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage by the implementation of appropriate technical and organisational measures; and
• Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data 

Personal data

Personal data is defined as data which relates to a living individual who can be identified from that data or other information which in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

Personal data only includes information relating to natural persons who:

• can be identified or who are identifiable, directly from the information in question; or
• who can be indirectly identified from that information in combination with other information

Personal data may also include special categories of personal data or criminal conviction and offences data. These are considered to be more sensitive and you may only process them in more limited circumstances.

Information about a deceased person does not constitute personal data and therefore is not subject to the GDPR.

Personal data

UKHab Ltd only holds personal data which is directly relevant to its directors and employees. That data will be held and processed in accordance with the data protection principles and these regulations.

Other person’s personal data

Information relating to individuals will be obtained for the delivery of services. This could include confidential information such as names, addresses, credit or debit card details, bank details etc. Care is taken to ensure that the information being obtained is adequate, relevant and not excessive for the purpose it is intended to be used for. The information will not be processed or stored in any manner incompatible with that purpose. The information will be kept safe from unauthorised access, accidental loss or destruction, and will not be maintained for longer than is necessary.

Retention of Data

Data will only be retained for the periods as set out under existing legal frameworks. These are set out in UKHab Ltd’sData Retention Policy.

Access to data

Individuals have the right to access any personal data maintained about them electronically or in paper files. The application must be made in writing. Upon receipt of a Subject Access Request, The Organisation shall have a maximum period of 40 days within which to respond.

UKHab Ltd has the right, under the law, to charge a fee to process this access request.

Data breach

UKHab Ltd will notify the GDPR of data breaches where appropriate. This will be done without undue delay. the organisation will provide a reasoned justification if this timeframe cannot be met. Where relevant, the data manager (or other suitable person) will also notify the affected data subject without undue delay. Additionally, UKHab Ltd will also contact the UK ICO in the event that a serious breach has occurred.

The Organisation will not notify the ICO if the breach is unlikely to result in a risk to the rights and freedoms of individuals. The threshold for notification to data subjects is that there is likely to be a “high risk” to their rights and freedoms.

Consent

UKHab Ltd ensures that any request for consent will be written, prominent and separate from any business terms and conditions that may need agreeing to. We will specify in clear, plain language why we require personal data and what our intentions are relating to the data.

UKHab Ltd. will name our organisation and any third parties that data may be shared within any communication or correspondence relating directly to consent.

UKHab Ltd. will make it clear and easy for the individuals to withdraw their consent at any time and publicise how to do so.  The Organisation will act on withdrawals of consent as soon as practicably possible and no individual will be penalised for wishing to withdraw their consent. 

PRIVACY POLICY

This privacy notice informs you of how, when and why UKHab Ltd collects personal data and lets you know how your personal data will be used.

The information we may collect:

UKHab Ltd is committed to maintaining the privacy of all individuals with whom we interact. We may collect or obtain information about you from different places including:

• directly from you
• from a third party acting on your behalf e.g. an intermediary or broker
• from publicly available sources
• when we generate it ourselves
• from other organisations.

We will only collect information about you in line with relevant regulations and law. This information may relate to any of the materials or services we offer.

We do not capture or store any personally-identifying information (such as your e-mail address, name, title, or postal address) without your knowledge when you visit our website. You are always able to choose whether or not to provide such information to us.

How we might use your information

Any data you do provide, via our website or as part of our working relationship with you will be treated in the strictest confidence and held securely. We will only use your data for the activities that you have consented to.

Website Visitor Tracking

To maintain and improve site quality and integrity, website usage is tracked may be tracked. All data that is tracked is anonymous.

Other sites to which we provide links may be governed by different policies. We do not assume responsibility for the content or information practices of these other websites, and we strongly encourage you to review the privacy statements and policies of all externally-linked websites.

Use of Cookies

Cookies are small text files that are stored on the devices (computer/tablet/mobile) to access our website.

UKHab Ltd uses cookies to improve the user experience and to provide us with information about how our website is used so that we can make sure it is up to date, relevant and error-free.

The following types of cookies are used on this website:

• Session Cookies: These basic cookies are used to carry out the essential functions on websites, such as identifying you as a user, remembering you from page to page within the website, and maintaining log in details for the session or a transaction. These expire as soon as you close your browser, or after a short period of typically 20 minutes of inactivity.
• Persistent Cookies: These are the small text files that are created in the cookies folder of your web browser by the website. They can contain information to record specific browsing information such as how you reached the website, the pages you view, options you select, and the path you have taken through the site. These typically remain in your cookies folder.

COOKIE	DESCRIPTION	Length
__cfduid	The cookie is set by CloudFare. The cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.	1 month
cookielawinfo-checkbox-necessary	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Necessary”.	1 year
cookielawinfo-checkbox-non-necessary	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Non-necessary”.	1 year

Using ukhab.org means you agree to the use of cookies in the manner described above. You can choose to restrict cookies set on ukhab.org through your browser settings at any time. For more information about how to do this, and about cookies in general, you can visit www.allaboutcookies.org.

Your consent and control

Before cookies are placed on your device you will see a banner at the top of your screen requesting your consent to set those cookies. By giving your consent, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent for any cookies other than those which are strictly necessary; however certain features of our site may then not function as intended.

You will be given the opportunity to allow or deny different categories of cookie that we use. You can return to your cookie preferences to review this at any time.

E-newsletters and emails

We may provide updates relating to UKHab by e-newsletter or emails. We want to give you control over our use of your data for direct marketing purposes. You can opt-out of receiving emails or e-newsletters from us at any time by unsubscribing using the link provided or by emailing contact@ukhab.org

Who we can share your information with

We may share your information with other companies we work in partnership with. We may also share your information with others outside of UKHab Ltd e.g. government authorities, sub-contractors or suppliers providing services on our behalf. We will obtain your agreement if data is shared with third-parties.

Links to other websites

This privacy notice does not cover the links within the UKHab.org website linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Data Security

Personal data collected from the website is held within a secure environment and follows the Data Protection Principles set out above.

Data Retention Policy

We will keep your information for as long as you have a relationship with us. After it ends we will keep it where we may need it for our legitimate purposes – for example. to help us respond to queries or complaints, or for other reasons.

Personal data collected for marketing purposes is retained for a period of three years.

Personal data collected relating to enquiries that do not result in licences – records are retained for up to 3 years and then destroyed.

Personal data relating to enquiries that result in signed licences – records are retained for 7 years and then destroyed

Records relating to signed licences – records are permanently retained, or are retained for 7 years after licence termination.

Your rights

You have a number of rights relating to your information e.g. to see what we hold, to ask us to share it with another party, ask us to update incorrect or incomplete details, to object to or restrict processing of it, to make a complaint etc. Contact us at the address below.

You can read more about these rights at the Information Commissioner’s Office.

Queries or complaints

UKHab Ltd takes the security of personal data very seriously. Please let us know if you feel the collection or use of personal information is in any way unfair, misleading or inappropriate.

If you have any queries on the processes we use to collect or store data or have any suggestions on how we could improve our processes please do get in touch with our Data Manager – contact@ukhab.org

Similarly, if you want to make a complaint about the way we have processed your personal information, we would first ask that you contact us directly to discuss this and allow us to remedy the situation. You are also able to lodge a complaint with the Information Commissioner Office (ICO), the statutory body which oversees data protection law. Details of how to do this can be found on their website www.ico.org.uk/concerns .

Changes to this privacy notice

We keep our privacy notice under regular review and may periodically make changes to this notice. We recommend that you revisit this Privacy Notice and our other policies on occasion to learn of any changes. This privacy notice was last updated on 07/09/2020.

How to contact us

If you have any questions or concerns regarding these policies, please direct them the Data Manager, contact@ukhab.org