Privacy Policy
This Privacy Policy (the “Notice”) explains what personal data (information) we hold about you, how we collect it and how we use and may share information about you for marketing purposes. We are required to notify you of this information under data protection legislation, including the General Data Protection Regulation. Please ensure that you read this Notice carefully and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
About Us
The Disability Passport, registered at Swandec 550 Valley Road, Nottingham, England, NG5 1JJ (the “Firm”) is a ‘data controller’ for the purpose of relevant data protection legislation, including the General Data Protection Regulation (“GDPR”) for the information which it collects for marketing, recruitment and employment purposes.
The Firm also acts as a ‘data processor’ on behalf of our members who provide legal services; a separate Privacy Notice is available for provision of these services and can be viewed by visiting our website at www.disability-passport.com
Website, digital platforms & cookies
Please note that our website, www.disability-passport.com and other digital platforms may contain links to third party websites / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our own digital platforms and therefore we recommend that you check the privacy and security policies of each and every other website / digital platform that you visit.
In common with many other website operators, we use standard technology called ‘cookies’ on our website. Cookies are small pieces of information that are stored by the browser on your computer’s hard drive and they are used to record how you navigate websites on each visit.
For further information on how we use cookies you can access a copy of our Cookie Policy by visiting our website.
What information do we collect?
All personal information that we collect about you will be recorded, used and protected by us in accordance with applicable data protection legislation, including the General Data Protection Regulation and this Notice.
We may supplement the information that you provide with other information that we obtain from our dealings with you, however we will not use that information for purposes which are not clear when you provide your details.
We may collect the following information about you when you enquire about our services:
- Name
- Date of Birth
- NI Number
- Address
- Email address
- Telephone number
- Details of your disability
How and why we collect the information
We may collect this information from you directly through the online contact forms on our website, on email, in person or via other digital platforms including social media.
We use your data for the following purposes:
- To administer and provide products and services you request or have expressed an interest in;
- To enable us to communicate with you about services that you have requested or expressed an interest in;
- To communicate with you in the event that any services you have requested are unavailable;
- For record keeping purposes;
- To create an individual profile for you so that we can understand and respect your preferences;
- To personalise and/or tailor marketing communications to you, and
When you interact with our digital platforms, we may also automatically collect the following information about your visit:
- How you have reached our digital platform and the internet protocol (IP) address you have used;
- Your browser type, versions and plug-ins and your operating system;
- Your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page and other page interaction information;
- Information collected in any forms you complete such as our online enquiry forms, and
- News, offers and opportunities from us
The processing of personal data is necessary for the purposes of legitimate interests pursued by the Disability Passport, such as, for the purpose of providing services and to tailor our communications to you in line with your preferences.
We do not process special categories of personal data for marketing purposes.
Your data and how we use it
Sharing Information
We will not use your data for purposes that are not clear when you provide your details and will not disclose data outside of The Disability Passport except in limited circumstances which are outlined below.
We may share your data with third parties where (a) if we are under a legal or regulatory duty to do so, (b) if it is necessary to do so to enforce our contractual rights, (c) to lawfully assist the police or security services with the prevention and detection of crime or terrorist activity, (d) where such disclosure is necessary to protect the safety or security of any persons and/or, (e) otherwise as permitted under applicable law.
Transfer of data outside the EEA
Please note that the Firm does not transfer data outside of the EEA for marketing purposes. In the event there is a requirement to transfer data outside of the EEA from time to time, we will take all necessary steps to ensure the data is afforded the same safeguards and controls as those applied within the EEA.
Data Retention
The Firm will retain your data for as long as is reasonably necessary for the required services to be provided to you and will not be retained indefinitely or for reasons incompatible with relevant data protection legislation, including the General Data Protection Regulation.
Your Rights
Under the General Data Protection Regulation, you have a number of important rights regarding your personal information. In summary these rights are as follows and include the right to:
- Request access to personal information;
- Request inaccurate information to be reviewed and corrected;
- Request a restriction to the processing of personal information;
- Request personal information held by the Firm to be erased in certain circumstances;
- Request a copy of the personal information that has been provided to us;
- Object to the processing of personal information or the continued processing of personal information, and
- Request not to be subject to automated decision making which produces legal effects that concern or affect you in a significantly similar way
Further information regarding the rights under the General Data Protection Regulation can be found by visiting https://www.ico.org.uk. These rights are subject to the conditions and restrictions set out in the General Data Protection Regulation and the Data Protection Act 2018.
Should you wish to make a request to exercise any of the above rights you should contact us via email at chris.fry@disability-passport.com or write to us at:
Compliance Officer
Disability Passport C.I.C, Swandec, 550 Basford Road, Nottingham NG5 1JJ.
When contacting us please ensure that you provide relevant information to allow us to identify you (this can include confirmation of any of the unique or personal identifiers we hold about you such as address) and state the right or rights that you wish to exercise. We may need to contact you to request further information to verify your identity.
We will respond to you within one month from when we receive a valid request.
Keeping your personal information secure
We take the security of personal information seriously and the Firm has appropriate measures, safeguards and protocols in place to ensure that data is kept secure, is only accessed by those individuals authorised to do so and where there is a legitimate need to access the data. Appropriate and reasonable steps are in place to reduce the risk of unauthorised access to personal data held by the Firm (either through accidental disclosure or deliberate act) and in line with the Firm’ obligations under applicable data protection legislation, including the General Data Protection Regulation.
Where to make a complaint
If you have a complaint regarding any aspect of your personal data or this Notice, please write to us via enquiries@frylaw.co.uk or at the above address.
If you are not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
You can also contact the Information Commissioner’s Office by visiting their website https://www.ico.org.uk.
Changes to this privacy notice
We aim to meet high standards and so our policies and processes are subject to review. From time to time we may change this Notice and will inform you, usually in writing or by publishing updated content to our website, www.disability-passport.com