The Silva Navigation School is a trading name of Pete Hawkins Ltd and holds personal data in accordance with the legislation contained within the The General Data Protection Regulation.
Data Protection Notice
At Pete Hawkins Ltd, we are committed to protecting the privacy of your personal data in accordance with Data Protection legislation. This Data Protection Notice establishes the basis on which we will process your personal data.
In this Notice, ‘we’ (and any related expression) refers to Pete Hawkins Ltd, registered in England & Wales, no. 459643 whose office is at 1 Bull’s Head Courtyard, Commercial Road, Tideswell, Derbyshire SK17 8NU.
This Notice applies whether you are, or you are acting on behalf of, a customer or a potential customer.
The Data Protection Legislation
As from 25th May 2018, most personal data processing in the UK is subject to the EU General Data Protection Regulation (`GDPR’), as supplemented by UK legislation.
Personal data is any information that directly or indirectly identifies a living individual.
For the purposes of the GDPR, we will be the controller of any personal data that we collect from or about you in connection with the provision of our professional services, or related activities such as promoting the Group’s business and market research or, where relevant, dealing with job applications.
Under the GDPR, data controllers are required to process personal data lawfully, fairly and in a transparent manner, and in a manner that ensures appropriate security of the personal data. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes, and the data must be adequate, relevant and limited to what is necessary in relation to those purposes, accurate and, where necessary, kept up to date, and kept in a form which permits identification of data subjects for no longer than is necessary for those purposes. Data controllers are responsible for, and must able to demonstrate, compliance with these principles.
What personal data do we collect from or about you?
If you make an enquiry
If you contact us with an enquiry about our services (either through the website or by phone, email or post), we will ask you to supply essential contact details (your name, e-mail address, phone number and, where applicable, the company or other person you represent and your job title), which we need in order to identify you and deal with your enquiry.
Depending on the nature of your enquiry, we may collect from you further details, such as the circumstances in which you are making the enquiry and the services that may be of interest to you and related information.
If you are or become a customer
If you are or become a customer by signing up on a course or walk we operate, or by purchasing a physical product from our ecommerce shop (whether that is a free or paid-for product), and in the course of providing our professional services, we may collect further personal data from you, depending on the nature of the services we are providing. In certain cases, the information that we collect from you may be of a sensitive nature (for instance, health related information), but we will only ask you to provide the information that is necessary and appropriate for the activity you have purchased.
If you do not provide us with the information we need, we may not be able to provide our professional services for you or the company or other person you represent.
When you make a personal payment for our services, details of the method of payment, your bank details or your credit or debit card number will be processed but is handled by compliant third parties (Stripe or Paypal). We have no access to any of this data
Why and on what basis do we process your personal data?
When you make an enquiry, we will process the personal data that you give us, or we collect from you or about you, so that we can supply you with the information that you have requested about our professional services, on the basis that it is necessary for our legitimate interests in promoting and marketing our professional services, or in order to provide a quotation for our services.
If you are or become a customer (or the company or other person you represent is or becomes a customer), we will process the personal data that you give us, or we collect from you or about you, in order to perform the contract that we have with you (or the company or other person you represent).
Where we need to process special categories of data (‘sensitive data’) relating to you, we will only do so with your explicit consent or where this is necessary for the establishment, exercise or defence of legal claims.
We will also process your personal data for internal record keeping, billing and accounting, and to respond to any queries, complaints or requests for further information, and for the purposes of archiving. The basis on which we do so is that it is necessary for our performance of the contract we have with you (or the company or other person you represent), or is necessary for our legitimate interests in managing our business and improving our professional services.
In appropriate circumstances (specifically on courses that offer qualifications offered by the National Navigation Award Scheme (https://nnas.org.uk) we will use the personal data that you provide or that we collect about you so we can process your course application and subsequent course administration. (More details of this is included in the Who do we Share your personal data section below).
When you buy a physical product (or a downloadable free product), we collect enough information from you to enable us to process that order and dispatch the item to you. In order to receive further occasional information from us you must opt in. Order details are kept for five years, pending, failed or cancelled orders are kept for 10 days, after which they are automatically deleted..
Staying in touch
We send out occasional email communications to customers (using Mailchimp’s services) who wish to receive it. All such communications have a simple unsubscribe option – or you may request us to delete your subscription from Mailchimp and our own database.
Who do we share your personal data with?
We will not use your personal data for any other purpose, or disclose it to any third party, without your consent unless we are required to do so by law, or as mentioned in this section.
Data processing services
The Bronze, Silver and Gold courses along with the NNAS Tutor award are all courses accredited by the NNAS and in order for the NNAS to legitimately process that data and administer the awards, your data is entered in the NNAS’s Candidate Management System (CMS).
NNAS is registered with the Information Commissioner’s Office (ICO).
Compliance with legal obligations
Pete Hawkins Ltd is registered as a Data Controller with the Information Commissioner’s Office
We may disclose your personal data if we are required to do so in order to comply with any legal or regulatory obligation or request, or where we have a legitimate interest in doing so, such as in order to enforce or apply our contract with you, to investigate potential breaches, or to protect our property and rights or those of others.
Where we keep your data?
Data is stored either on a personal computer at the Office of Pete Hawkins Ltd or on the UK-based server used to host the Silva Navigation School’s website. In both cases, the data is secured by encryption and secured behind firewalls. Where such data is also available on mobile devices, these are secured by best practice methods.
How long do we keep personal data for?
If you contact us with an enquiry about our professional services but you do not subsequently become a customer (or the company or other person you represent does not do so), it is our policy to delete your personal data after twelve months.
If you are or become a customer (or the company or other person you represent is or becomes a customer), we normally retain contract information (including personal data) for a minimum period after the end of the relevant contract or client relationship, or for longer where it is necessary for us to do so for compliance with regulatory or other legal obligations. In some cases it may be necessary for us to retain records indefinitely.
Once we delete data held on you from our system, it may stay on the Mailchimp database until you request us to delete it, or you choose the unsubscribe option.
Our full data retention policy is available on request.
Personal data relating to our professional contacts will be retained for so long as is necessary, or until you indicate otherwise to us, but we will aim to update our contacts’ preferences on a periodic basis.
In certain cases, it may not be physically possible to delete certain data (for instance, where it is stored on a secure external server), in which case we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.
Your rights as a data subject
As a data subject, you have certain legal rights (subject to certain exceptions under the Data Protection legislation) including the right:
- to access the personal data held about you and request a copy of it;
- to ask us not to process your personal data for marketing purposes;
- to withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your personal data on the basis of a consent that you have given (and not on some other legal basis);
- to ask us to rectify inaccurate personal data about you;
- to ask for the restriction of personal data about you that is inaccurate, unlawfully processed, or no longer required;
- to ask for the transfer of your personal data in a structured, commonly used and machine readable format where appropriate;
- to ask for the erasure of personal data about you where processing is no longer necessary, or the legitimate interests we have in processing your personal data are overridden by your interests, rights and freedoms as the data subject; and
- to make a complaint to the Information Commissioner’s Office which can be contacted by post via: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone via 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Changes to this Data Protection Notice
We may change this Data Protection Notice from time to time. In the case of any substantial change, we will notify you (where practicable) in writing or by email.
How to Contact Us
If you have any questions, comments or requests about this Data Protection Notice, or would like to exercise any of the rights you have, as set out above, please contact us:
- by email to: firstname.lastname@example.org; or
- by post to: Pete Hawkins (Data Controller), Silva Navigation School, 1 Bull’s Head Courtyard, Commercial Road, Tideswell, Derbyshire, SK17 8NU.