JCC Consultants Limited GDPR and Privacy Policy
Key Details
Prepared and approved by: John Needham, Director
Effective from 11/01/2020. Next review date: January 2021
Your Personal Data
Personal data relates to a natural living individual who can be identified from that data.
Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.
The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
Who We Are
We are JCC Consultants Ltd. We provide the following services:
Water Rescue Training and Consultancy
Commercial Diving Services
Recreational Diving Training
First Aid Training
How Do We Process Your Personal Data
JCC Consultants Ltd complies with its obligations under the “GDPR” by
keeping personal data up to date;
storing and destroying it securely;
collecting or retaining only required and legitimate data;
protecting personal data from loss, misuse, unauthorised access or disclosure
ensuring that appropriate technical measures are in place to protect personal data.
How We Collect and Use Personal Data
We collect your Personal Data in a number of ways and for various purposes, including:
When you register for a course or activity we will ask for
When you communicate with us or sign up for promotional materials.
When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes.
How We Disclose Personal Data
Your personal data will be treated as strictly confidential and will only be shared with others for purposes connected with the the issuing of certificates by and registration with our Awarding Bodies. For further information on legitimate interests please see our website at www.jccdivingwaterrescue/GDPR&PrivacyPolicy. We will only share your data with third parties with your consent (see additional consent form). In particular we will share your data for:
For the production and recording of certificates of attendance and qualifications
To comply with external training/certification agencies record keeping requirements
For Legal Compliance, Law Enforcement, and Public Safety Purposes
What We Use Your Personal Data For
to enable us to provide a responsible and safe course or event for our clients;
to administer assessments, progress and records;
to manage our staff and volunteers;
to maintain our own accounts and records;
to inform you of news, events, activities and services run by JCC Consultants Ltd;
to share your contact details with our awarding bodies so they can award certificates, and register you as a learner.
Legal Basis for Processing your Data (Lawful Basis)
For the purposes of applicable data protection laws, JCC Consultants Ltd is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy.
In case of questions about the processing of your Personal Data please contact us via our contacts page or in writing at the address given, under Contacting us, at the end of this document.
We collect and process your Personal Data for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including:
Vital Interests
Criminal Conviction Data
For the performance of a contract
To meet legal obligations
For Legitimate Interests
Consent As A Basis For Processing
In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when providing us with your Personal Data through our Services or a form. We may request your consent for a number of activities including:
Processing sensitive Personal Data.
Withdrawing Consent
You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection. Please contact us via the contacts page regarding this.
Data Retention
We will retain your Personal Data for as long as is necessary to provide you agreed Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For qualifications having legitimacy periods, such as 3-year first aid qualifications, etc, we will retain your data for up to 2 years after the expiry date. Data pertaining to accidents or complaints will be retained in accordance with current legislation.
Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.
Where permissible, we will also delete your Personal Data upon your request. For information on how to make a deletion request contact us via the contacts page on our website. Specifically, we retain data while it is still current on:
learner / participant’s name address and unique learner number / registration number
telephone mobile numbers of those with parental responsibility for contact only
medical / injury information
Your Rights And Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of your personal data which JCC Consultants Ltd holds about you;
The right to request that JCC Consultants Ltd corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for JCC Conustants Ltd to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that the data controller provide the data subject with his / her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing;
The right to object to the processing of personal data: this applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of educational research and statistics).
The right to lodge a complaint with the Information Commissioners Office.
Further Processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Security
We implement appropriate technical and organisational safeguards to protect against unauthorised or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
Links to Other Websites
This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may from time to time provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.
Children
We do not knowingly collect Personal Data online from children under 13. If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our contact page on our website. If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the data.
How to Contact Us
To exercise all relevant rights, queries of complaints please in the first instance contact:
JCC Consultants Ltd
74A Westbury Leigh
Westbury
Wiltshire
BA13 3SQ
Further information can be obtained from the Information Commissioners Office