1 Personal Information
1.2 Door Supervisor Training Organisation (DSTO) (we, us, our) is a registered data controller under the terms of the Data Protection Act 1998. Details of our notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at ico.org.uk under registration number Z8627261. Our registered office address is Door Supervisor Training Organisation C/O Stephenson and Co, Austin House, 43 Poole Road, Bournemouth. BH4 9DN.
1.3 Our Data Protection Officer is Kate Stephenson.
2 General Information
• (a) visit our websites at:
o (i) www.dsto.co.uk(our Main Website); or
o (ii) www.traininginsecurity.co.uk (our Sister Website)
(together, the Websites);
• (b) register an account with us on our Public Networks Website (Your Account) and how we handle your information in respect of our agreement with you to provide recruitment services (together, our Services) to ensure that we protect your rights.
3 What information do we collect?
3.1 When you use the Websites and or our Services we may ask you to provide certain information such as, your name, date of birth, place of birth, contact details (including your address, email address, and contact telephone number).
3.2 When you register Your Account with us on our Public Networks Website or wish to receive marketing information listed on our Main Website, we may also ask you to provide certain information including:
• your name, date of birth, place of birth, contact details including your address, email address, and contact telephone number.
4 What do we use your information for?
4.1 You have the right to be told the legal basis and purposes for the processing of your personal data. We are relying on your explicit consent to the processing of your personal data. This means that if you exercise your right to withdraw your consent (please see paragraph 8 below) we will no longer be able to process your data. Please note we may retain a copy of your data in accordance with our data retention policy.
4.2 We may use your information for the following purposes:
• (a) to:
o (i) manage Your Account, process any information provided by you to us and to store your personal data in our databases;
o (ii) process any orders for products advertised on the Websites and manage the order process, including contacting and liaising with suppliers and manufacturers in relation to your order;
o (iii) assess your buying patterns to ascertain your suitability for special offers and promotions we may be running
o (iv) pre-populate fields on our Public Networks Website and on order forms that are advertised on our Websites to make it easier for you to provide information when you return to our Websites but you may remove pre-populated data before submitting the order
o (v) discuss with our manufacturing contacts the suitability of certain products or services that you have expressed an interest in or which we think you may be interested in or that may be suitable, on the basis that such processing is necessary in order to perform our Services;
• (b) for our own market intelligence gathering purposes, to enable us to understand the PPE, Safety equipment and work wear market and prepare demographic, analytical, statistical or market information (which may include aggregating your data with, and benchmarking it against, data received from other individuals, clients and suppliers/manufacturers) and to improve our services (all on the basis that your personal data will be completely ammonised and you will not be capable of being identified from such information if we share it externally);
• (c) for such purposes as are reasonably necessary to comply with any legal obligations to which we are subject in the performance of our Services; and
• (d) to communicate with you, including sending you information about offers and promotions, which we think may be of interest to you and to send you event invites, newsletters and updates on the basis that you have given your consent to such processing by opting-in to receiving marketing information from us on the Manage My Profile page on Your Account. You will be able to opt-out of such communications at any time by contacting us using the contact details in paragraph 12, below, or by opting-out of receiving marketing information from us via the “Manage My Profile” page on Your Account.
4.3 Please note that we may also use your personal data to prepare, use and disclose statistical and demographic information regarding use of the Websites for the purposes of improving the Websites (in pursuit of the legitimate interests of improving the Websites for the benefit of you and our other clients to whom we provide our Services) and for our marketing purposes (in no circumstances will you be capable of being identified from such statistical and demographic information).
4.4 We shall periodically check that the personal data we store for you is accurate. If you would like to update the personal data we hold about you, please contact us with your request using the contact details at paragraph 12, below or by logging-in to Your Account and updating your personal details on the Manage My Profile page on Your Account.
5 Who do we share your information with?
5.1 As part of using our Services, you consent to us sharing your personal information with the following parties:
• (a) our data hosting/support service providers who process and store data on our behalf;
• (b) our professional advisors and consultants;
• (c) any of our group companies, including any companies which may be added to our group from time to time;
• (d) any of our business partners and employers with whom we share information for the purposes of identifying suitable products
• (e) our trusted third-party emailing service provider whom we use to upload and send email communications with you.
5.2 We may also share your personal information with third parties:
• (a) in the event that we or any of our group companies, our business, or substantially all of its assets are acquired by a third party (in which case personal information about customers will be one of the transferred assets);
• (b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
• (c) if such disclosure is necessary in connection with any law (including any investigation or complaint regarding your use of the Websites).
6 Transfers of personal data outside of the United Kingdom and the EEA
6.1 If you are registering Your Account, purchasing goods on our Websites and/or using our Services from:
• (a) within the United Kingdom and the European Economic Area (EEA), then we will not transfer your personal data outside of the United Kingdom and the EEA; or
• (b) outside of the United Kingdom and the EEA, then we may transfer your personal data outside of the United Kingdom and the EEA solely for the purposes of corresponding with you in relation to our Services.
6.2 We shall ensure that any such transfers outside of the United Kingdom and the EEA are lawful and with an adequate level of protection and that your personal is kept secure in accordance with the DPA 1998 (up to and including 24 May 2018) and the GDPR (from and including 25 May 2018).
7 How long do we store your personal data for?
7.1 We only store your personal information for as long as necessary for the purposes listed in paragraph 4.
8 What are your rights?
8.2 Access to your personal data: You may request access to a copy of your personal data by contacting us using the contact details in paragraph 12.
8.3 Right to withdraw: You may withdraw your consent to us processing your personal data at any time. Please contact us using the details located at paragraph 12 if you would like to withdraw your consent and we will delete your data in line with your right to erasure at paragraph 8.5 below. Please note that in the event that you wish to exercise your rights under this paragraph 8.3, we may be unable to process your application any further (including any in-flight applications) or continue to provide our Services to you.
8.4 Rectification: You may ask us to rectify inaccurate information held about you. If you would like to update the data we hold about you, please contact us using the details in paragraph 12 or by logging-in to Your Account and updating your information on the “Manage My Profile” page accordingly.
8.5 Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us using the contact details in paragraph 12 and specify why you would like us to delete your personal data. Please note that in the event that you wish to exercise your rights under this paragraph 8.5, we may be unable to process your application any further (including any in-flight applications) or continue to provide our Services to you.
8.6 Portability: You may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller by contacting us using the contact details in paragraph 12.
8.8 Make a complaint: You may make a complaint about our data processing activities to a supervisory authority, for the UK this is the Information Commissioner’s Office, at ico.org.uk.
9 Cookies Policy
9.1 Certain parts of the Websites use “Cookies” to keep track of your visit and to help you navigate between sections. What are Cookies?
9.2 A Cookie is a small data file that certain websites store on your computer’s hard-drive when you visit such websites. Cookies can contain information such as your user ID and the pages you have visited.
How do I reject or accept Cookies?
9.4 You may refuse to accept Cookies by activating the setting on your browser, which allows you to refuse the setting of Cookies. If, however, you select this setting you may be unable to complete an application for any job vacancies contained on our Websites as the information you provide will be lost as you navigate between pages on the Websites.
9.5 See http://www.allaboutcookies.org for more information about Cookies and how to disable them in your browser.
10 Security and Data Storage
10.1 We will treat all of your information in strict confidence and we will endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. We adopt and ensure any third party suppliers providing services on our behalf adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, and data stored on the Websites and associated databases.
10.2 Please note that the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us liable for any breaches of your data protection rights attributable to the transmission of your personal data over the internet.
10.3 The use of CCTV may be necessary either during training courses or at the premises in which the training courses are operated. The information that is stored is done so using the Freedom of Information Act and RIPA. All information will also be stored using PACE guidance.
12. Mediums used to Contact you
12.1 The ways we may make contact with you are as follows:
• Social Media
• In person/face to face
The method used will be either your preferred method of contact or the one most appropriate for the type of communication required.
13 Contact Us
• (a) our privacy team at firstname.lastname@example.org (or such other email address as may be displayed on the “Contact Us” section of any of the Websites from time to time); or
• (b) our Data Protection Officer by post at Door Supervisor Training Organisation, Unit 11, Wessex Trade Centre, Ringwood Road, Poole. BH12 3PF.