We are registered with the ICO and our registration number is ZB392134.
What personal data we collect and why?
At Composure Media Ltd we will only collect the minimum personal information from you. This will be at the point you contact us, ask to be included on a newsletter, ask for further information or become a client.
This could include your name, address, telephone numbers, email address, signature, training film footage and bank account details. We need this information for legitimate, contractual or organisational purposes to provide you with the services that you have requested. We will not use your data for any other purpose unless we have obtained your consent for that specific purpose such as marketing.
We need this information to process your requests and we do not regard it as excessive. Other relevant details that you provide in relation to the services you receive from us may be added to your data, but anything not required will be deleted immediately. We will not ask for any irrelevant information. We will not hold or process any special category personal data at any time. If your contact details change, please advise us and we will update our records accordingly.
We do not carry out automated decision making or any type of automated profiling.
We will always process your data in a fair and lawful way in accordance with article 5 and article 6 of the GDPR.
We regularly conduct data flows and a data inventory or data audit which looks at all aspects of the personal data that we process, including the legal basis for processing and any special requirements that the data needs. Any risk assessments (DPIAs) requirements are identified and completed paying particular attention to privacy risks associated with each processing activity: storage, collection, transmission, access and deletion.
We regularly complete Legitimate Interest Assessments to ensure that our marketing activities are considered, appropriate and are in accordance with all relevant legislation.
We will never knowingly collect data from or on children below 13 years old.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. This is in accordance with our Data Protection Policy. Your data maybe used by the Composure Media Ltd team who have a legitimate business need to know such data. We will only process your personal data in accordance with our business processes where the safety of your data is paramount.
Who do we share your personal data with?
We use limited third parties in conjunction with routine business requirements.
With professional advisors such as accountants and insurance, although this information will be very limited;
In order to conduct checks on you to verify the information you have provided us with where you are being considered for a position or contract with us;
In the event of a sale of the company or its assets;
With suppliers but only subject to robust contractual protections;
If we are legally obliged to do so.
To provide our services to our clients we also specifically use:
Please note that we do not require your consent to share this information if we suspect criminal or unlawful activity, in these circumstances we will only contact the relevant organisations.
At no point will your personal data be sold to anyone else and if we do need to share your data to a relevant third party, we will obtain your consent first.
We have procedures in place to deal with any suspected personal data breach and will notify you and any supervisory body of a breach if we are legally required to.
We will not transfer your personal information outside of the EU without ensuring the correct data protection is in place.
Retaining your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our data retention policy considers the amount of data, its nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes and if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. We will delete all personal data in line with our data retention schedule which is reviewed regularly.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. You will not be recognisable as a natural living person from this anonymised data.
If you contact us via our website, we assume that by contacting us you would like us to respond, your consent will be implied. In order to process your enquiry we need your contact details to do so.
We will not add your details to any mailing list without you consenting to receive them. If you do opt in to receive update and newsletters from us, you can opt out or unsubscribe at any time. Please contact us at: email@example.com . This can be done at any time.
There will be occasions where we do not need your consent to contact you and will rely on a legitimate business reason as in to contact you about services you have expressed an interest in or a contractual obligation to fulfil a business commitment e.g. to pay you or to provide services. If you wish to make a comment on our website, you may be asked for your email address so that we can respond to you.
The GDPR provides the following rights for individuals:
What does this mean?
1. The right to be informed
2. The right of access
You have the right to obtain access to your information . This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification
You are entitled to have your information corrected if its inaccurate or incomplete.
4. The right to erasure
This is also known as the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right, there are exceptions.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. This is not a normal scenario for companies of our nature but if you have any questions you can contact us.
7. The right to object to processing
You have the right to object to certain types of automated processing or decision making, including processing for direct marketing or where we are relying on our legitimate interests for processing.
8. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
You have a right to see what information that we hold about you and you can get in contact with our Data Protection Officer at the following address: firstname.lastname@example.org
Under the GDPR you have the right to request a copy of the personal information Composure Media Ltd hold about you and to have any inaccuracies corrected or information deleted. You will need to prove your identity with 2 pieces of approved identification which can be a: passport, driving licence, birth certificate, utility bill (from last 3 months), current vehicle registration document, bank statement (from last 3 months) or a rent book (from last 3 months). We will verify your identity, noting how and when we verified it, then we will immediately delete that data. We will send you a form which clarifies what information you are looking for and to verify your identity.
If you can advise of the specific information that you require, we can process your request more quickly. We will respond to your request within one month of you providing information that confirms your identity. You are obviously entitled to all your personal information.
We will respond within one month, giving you a copy of your data, why we have it, who it could be disclosed to, the categories of data it involves, and it will be in a format that you can access easily. You have the right to clarify and correct the information as necessary. It can be deleted providing that it is not required for legal or public interest reasons. If your request is more complex, for example it involves other data subjects and we need their consent to release the relevant information we can extend our response time to three months, but we will inform you of this. If they do not give their consent, we will anonymise this data or remove the relevant detail before sending this to you. We will not charge for data subject access requests unless they are excessive or manifestly unfounded. Then we will charge for administrative time only.
If you are not satisfied with our response, please get in touch and we will do our best to help you: email@example.com
Google analytics is used but does not identify any personal information. All data is aggregated and no personal information is either stored or analysed.
Concerns, Comments and Feedback
If you have any concerns about your data, or any comments or feedback about our services then please get in touch and we will do our best to help you: firstname.lastname@example.org
If you have any concerns about how your data is being used or processed and we have not been able to help you, then you can contact the ICO. Ways to report concerns are detailed on their website: https://ico.org.uk/concerns/ .