GCT Privacy Notice – GDPR Update

Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

GCT is pleased to provide the following Privacy Notice:

Personal Data

This Privacy Notice provides you with clear information as to how we process your personal data. We are obliged to use your information in line with all applicable laws. We do so in a manner that is fair by using your information in a way that you would reasonably expect when providing our services.

GCT uses the information collected from you to provide information on our products and services, provide training and consultancy services, make telephone contact and to email you marketing information which GCT believes may be of interest to you and your business. In you making initial contact you consent to GCT maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our websites, including but not limited to personally identifying information like Internet Protocol (IP) addresses. GCT may from time to time use such information to identify its visitors. GCT may also collect statistics about the behaviour of visitors to its websites.

The GCT websites use cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Our websites use cookies to help GCT identify and track visitors and their website access preferences. GCT website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the GCT websites.

Any information GCT holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

GCT will only collect the information needed so that it can provide you with membership, education, training, consulting and marketing services, GCT does not sell or broker your data.

Legal basis for processing any personal data

To meet GCT’s contractual obligations to its business partners and clients and to also respond to marketing enquiries.

To carry out the reasonable business requirements, namely: To inform our subscribers of GCT’s products and services.

You have the right to object to us processing your data based on legitimate interest, see last section for full contact details.

Consent

Through agreeing to this privacy notice you are consenting to GCT processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing or writing to us, see last section for full contact details.

Disclosure

GCT may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. GCT requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

GCT do not broker or pass on information gained from your engagement with us without your consent. However, GCT may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. GCT may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of GCT, its clients and/or the wider community.

Retention Policy

GCT will process personal data during the duration of any subscription or contractual relationship and will continue to store only the personal data needed for six years after the contractual relationship has expired to meet any legal obligations. After six years any personal data not needed will be deleted.

Data storage

Data is held in the EEA and the USA using different (multiple) servers. Where data is transferred to countries outside the EEA, we will ensure the appropriate safeguards are in place.

Your rights as a data subject

At any point whilst GCT is in possession of or processing your personal data, all data subjects have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

In the event that GCT refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

GCT at your request can confirm what information it holds about you and how it is processed

You can request the following information:

• Identity and the contact details of the person or organisation (GCT) that has determined how and why to process your data.
• Contact details of the Director General where applicable
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of GCT or a third party such as one of its clients, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (Data Protection Regulator).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

To access what personal data is held, identification will be required

GCT will accept the following forms of ID when information on your personal data is requested: a copy of your national ID card, driving license, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If GCT is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made by writing to privacy@gct.co 

Complaints

In the event that you wish to make a complaint about how your personal data is being processed GCT or its partners, you have the right to complain to GCT’s GDPR Officer. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

The details for each of these contacts are:

Matthew Campbell

Head of Operations

matthew.campbell@gct.co

Tel +44 (0)1707 903 601

Data Protection Regulator

The Information Commissioner’s Office Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone 0303 123 1113 or via their website https://ico.org.uk/