Your privacy is important to us. Purple Feather Tree are committed to keeping your information secure and processing all data in accordance with UK Domestic Data Protection law, EU Data Protection law. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller under registration number ZA934885.
Data submitted outside of UK and EU territory will be processed to UK law and/or in accordance with applicable law where there is a mandatory requirement that requires enhanced compliance.
All matters relating to our Data Protection compliance and policy are managed by the company Director, Alexandra Osbourne.
What Information We Collect
We process personal information which you give us:
What personal information we process
Special Categories of Personal Data
Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us, or it is relevant to Service you have asked us to provide; For example; personal career goals, or where you have advised us of an issue, such as your health, which could mean that you may be classed as a “vulnerable client” i.e. due to your personal circumstances or personal characteristics you are particularly vulnerable to financial detriment. We will process sensitive information where you have provided this information to us and have agreed that we can use this information to deliver relevant services and educational courses Where possible we shall seek to minimise the collection and use of such special categories of personal data.
How we might collect your Personal Data.
When you engage Purple Feather Tree to provide any of our services your data will be processed on the basis that you have contracted with us, this is a different lawful basis to the consent basis.
How we use your Personal Data.
When you provide us with your personal information, we use your information to:
We will process your information in order to meet our contractual obligations to you, where we have a legitimate interest to do so and, where we are permitted by law or to comply with applicable laws and regulation.
Providing a service and internal processing
To assess your needs and provide you with educational and development courses
The lawful basis is to fulfil all the contractual obligation.
To service and administer your matter including billing
Legitimate interests to provide and manage the service
To confirm, update and improve our client records
To comply with legal obligations in the Data Protection legislation
To provide you with any information on the services that you have requested
To meet our contractual obligation to provide information on the services you have requested
To manage and develop our relationship with you
Legitimate interest to service your matter and improve our service to you
To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this
With your consent
Training and development
For training purposes and to improve our service to you
Legitimate interests to improve our services and develop our employees
Complying with Legal Obligations
To prevent, investigate and prosecute crime, fraud and money laundering
To comply with legal obligations for prevention of financial crime and money laundering
For auditing purpose
To comply with our legitimate interest to conduct audits
If we are obliged to disclose information by reason of any law, regulation, or court order
To comply with legal obligations
To transfer information to any entity which may acquire rights in us
Legitimate interests for commercial interests
For any other purpose to which you agree.
With your consent
How we retain your personal information
We will retain your personal information in accordance with applicable laws. We will take reasonable steps to destroy or anonymise personal information we no longer need for the purposes we have set out above.
Our retention periods are:
Type of personal Information
General personal data which includes your normal personal data, personal identity and personal financial data
2 years after the end of our relationship with you.
Special categories of personal data
2 years after the end of our relationship with you
How we share your information
Where necessary or required we share information with:
In situations where it is necessary for data to be transferred between parties whether UK, EU or Worldwide we maintain optimum security protocols and have policy in place to continually monitor and safeguard all data.
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You have the right to request copies of your personal information. If you think any of the personal information, we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’, but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest.
In relation to all of these rights and on any other mater relating to Data Protection you may email firstname.lastname@example.org.
If you have a complaint about how we have handled your personal information you may contact us using the details above and we will investigate your complaint. If you are unhappy with any aspect of our investigation into your complaint you have the right to complain to the Information Commissioner’s Office, details of how to complain are available at www.ico.org.uk