This privacy notice describes how DCHarmonised (“We”, “Our”, “Us”) collect and use personal data about you, in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, Privacy and Electronic Communications Regulation and any other applicable laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

This privacy notice applies to all personal data we collect or process about you. Personal data is identifiable data, or a combination of pieces of data, that could reasonably allow you to be identified.

This notice will be updated from time to time to time, so please check it regularly. This notice is valid from and including 6th April 2024

1. ABOUT US

DCHARMONISED LTD is an Data Compliance and Analytics company. We are registered in England & Wales as a limited company under number 15240009 and our registered office is The Kiln, 2 Copenhagen Street, Worcester, WR1 3DL

2. DATA CONTROLLERSHIP

For the purpose of the Data Protection Legislation and this notice, we are the ‘Data Controller’. This means that we are responsible for deciding how we hold and process personal data about you. 

3. HOW WE COLLECT YOUR PERSONAL DATA

We obtain personal data about you directly from you when:

• You request a proposal from us in respect of the services we provide,
• We contract to provide consultancy services to you,
• You contact us by email, telephone, post or social media,
• You register and become a member of the DCH community,
• You register and attend one or more of the Webinars in the DCH community.

4. THE DATA WE COLLECT AND PROCESS ABOUT YOU

The information we hold about you includes, but is not limited to, the following:

• Your personal details (such as your name and/or address),
• Contact details, such as your email address and phone numbers,
• Your marketing preferences,
• Data relating to any complaints or enquiries you have made to us,
• Comments and other interactions on our social media platforms,
• Visits and interactions with our website.

5. LAWFUL BASIS FOR PROCESSING

In order to process your personal data, we are required to do so under a lawful basis as defined within the UK GDPR. Your data can be processed under one or more lawful basis. We processes your personal data under the following:

Contract – Where we have entered into a contract for the provision of our services with you, we will process your personal data in order to fulfil our contractual obligations.

Consent – Where you have provided consent to receive marketing communications, we will process your personal data to provide those communications to you.

Legitimate Interests – In order to improve our services and to gather feedback on our performance services, we will collect and process data from you, for which there is no obligation for you to provide.

6. HOW WE USE YOUR PERSONAL DATA

We may use your personal data in order to:

• In the preparation of quotes to you and you business
• To accurately respond to communications with DCH
• Register you for access to the DCH Community
• To make and/or receive payments in relation to our services,
• Notify you of any changes to our services,
• Provide you notification of any events to which you have consented to receive communications for,
• Provide data to third parties for which we have a legal obligation to report to,
• To seek your feedback and opinion in relation to the services we provide.

7. DATA RETENTION

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided,,
• any statutory or legal obligations,
• the purposes for which we originally collected the personal data,
• the lawful grounds on which we based our processing,
• the types of personal data we have collected,
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

8. CHANGE OF PURPOSE

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing. Your regulatory rights remain and any objection to the further processing that is incompatible with the original purpose.

9. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so to provide the services to you. We currently utilise the following sub-processors:

IONOS: Website provider and Email management:

Microsoft: Office365 is used as as our Email clients and the office products to produce quotes, documentation and other project or engagement collateral as required

Trello: Used for task management

Heartbeat: Used as the DCH community platform.

We may, from time to time, undertake to engage with additional resource and/or engage with other service providers to ensure the provision of the services to its clients are maintained. This may involve third parties outside the UK and the EEA. 

All of our third-party service providers (Data Processors) are required to take commercially reasonable and appropriate security and data protection measures to ensure the accurate processing and safety of your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

10. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

The data we directly collect from you will be predominantly processed in the UK. We may, from time to time, process your personal data outside the UK and/or EEA. Where this is necessary, we ensure the appropriate data transfer mechanisms are in place to provide you the security relating to that transfer. At this time, the UK IDTA (International Data Transfer Agreement) will be implemented as necessary to provide the required levels of security.

11. IS MY DATA SECURE?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way and to prevent it from being altered or disclosed accidentally.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have reason and need to process your personal data to provide the applicable services. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. YOUR RIGHTS

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us. Please see section 14: CONTACT US in order to submit your request.

Your rights in connection with personal data

Under the Data Protection Act 2018 you have the right to:

• Information: Request information on how we process your personal data. This privacy notice provides the transparency required in relation to this right, however further information can be requested if needed.
• Access: Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Rectification: Request correction of the personal data that we hold about you.
• Erasure: Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Objection: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Restriction: Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Portability: Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). 

13. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact, as detailed in section 14: CONTACT US.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

14. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact: privacy@dcharmonised.com

15. CONTACTING THE ICO

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows: 

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745 Website – https://ico.org.uk/concerns

16. CHANGES TO THE NOTICE

06.04.2024 - Initial Privacy Notice created