Cambridge Weight Plan

GDPR Privacy Notice

General Data Protection Regulation (GDPR)

Article 13 of Regulation EU 2016/670

1. Purpose of this notice

This Private Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice as explained in the appendix.

2. The Data Controller for personal data

We, Cambridge Weight Plan (CWP) are the Data Controller for the personal data processed by us. When you fill in CWP’s contact form to request a call back from a Consultant, you are in putting your personal data which is then collected, hereafter making you the “Data Subject”). The Data Controller will pass personal data of their Data Subjects on to their employees within CWP and on this occasion to the Consultant you are requesting a call back from. By you inputting your personal information into CWP’s contact form you are providing us with your information to process and asking us to pass your Personal Data on to a CWP Consultant for you. We will therefore need to use your personal data such as “email address” to request that the Consultant follows up on your enquiry.  By your inputting your information into our form you are consenting to us processing your data for the legitimate purpose of responding to your enquiry. This forms the “Legal Basis” for the processing of your personal data carried out by CWP in these circumstances. By your inputting your information into the enquiry form you are conducting an “affirmative action” that you wish to be contacted in relation to your enquiry. We will pass your personal data on to the CWP Consultant to whom you have requested contact from. They will also become a Data Controller of your personal data as once they have your enquiry request they will decide how to contact you.

3. Your Rights

As a Data Subject you have rights under the GDPR. These rights can be seen below. CWP will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

4. Contact Details

The identity and contact details for the Data Protection Officer within Cambridge Weight Plan is:

Ms Dannii Darling, Data Protection Officer
Cambridge Weight Plan
Hatton House
Hunters Road
Corby
Northamptonshire
NN17 5JE
Email: ddarling@cwp-uk.com

Should you wish to contact the Consultant to whom we have passed your data to for the purpose of responding to your enquiry and you do not have their contact details please contact us on the information provided above and we will provide you with their contact details for the purposes of exercising any rights you have under the GDPR.

5. Data Protection Principles

CWP has adopted the following principles to govern its collection and processing of Personal Data:

  • Personal Data shall be processed lawfully, fairly and in a transparent manner.
  • The Personal Data collected will only be those specifically require to fulfil the requirement – i.e. to respond to your enquiry. The data may only be collected directly from the Data Subject and such data will only be processed for that purpose.
  • Personal Data collected from the Data Subject shall only be retained for as long as it is required to fulfil the legitimate interests of the Data Subject – i.e. responding to your enquiry
  • Personal Data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
  • The Data Subject has the right to request from CWP access to and rectification or erasure of their Personal Data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case a request must be put in writing as to section 3 above to the contact details set out in section 4 above.
  • The Data Subject has the right to make a complaint directly to a supervisory authority within their own country. CWP’s Data Protection compliance is supervised by the:
    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow Cheshire
    England
    SK9 5AF
  • Personal Data shall only be processed based on the legal basis explained in section 2 above, except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (by contact the Data Protection Officer on the contact details as set out in section 4 above) (but may then result in the ability to suggest a suitable consultant)
  • CWP will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.

6. Transfers to Third Parties

To fulfil the requirements set out above (i.e. processing your data to pass your details on a third party (i.e. a CWP Consultant to respond to your enquiry) it will be necessary to process your personal data via a third party (this will only ever be the consultant whom you have required contact from for your enquiry). We confirm that Personal Data shall only be transferred to third parties, or processed by third parties where such third parties are necessary for the fulfilment of your request. We confirm that any third parties to whom we pass your personal data for processing will only retain your personal data for as long as is reasonable in order to perform the task the data is required for and that they will not process or store your data past how long the personal data is required.

We confirm that your Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the legitimate interest of CWP in regard to its contractual arrangements with its clients. Where we require to transfer or process your data outside the EEA and the country or territory is not recognised by the EU as having an adequate level of Data Security we will seek your permission in writing before the data is transferred or processed and we will also ensure that adequate Data Security is in place.

Appendix – Definitions of certain terms referred to above:

Personal Data:

(Article 4 of the GDPR): “personal data” means any information relating to an identified or identifiable natural person (“data subject”; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of that person.

Processing:

(Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.

Legal Basis for Processing:

(Article 6 of the GDPR): At least one of these must apply whenever Personal Data is processed:

  1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
  2. Contract: the processing is necessary for compliance with a Contract.
  3. Legal Obligation: the processing is necessary to comply with the law (not including contractual obligations).
  4. Vital Interests: the processing is necessary to protect someone’s life.
  5. Public Task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
  6. Legitimate Interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Data Controller:

(Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.

Data Subject Rights:

(Chapter 3 of the GDPR) each Data Subject has eight rights. These are:

  1. The right to be informed: this means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
  2. The right of access: this is your right to see what data is held about by you a Data Controller.
  3. The right to rectification: the right to have your data corrected or amended if what is held is incorrect in some way.
  4. The right to erasure: under certain circumstances you can ask for your personal data to be deleted. This is also called “the Right to be Forgotten”. The Right to be Forgotten is not absolute. It would however apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
  5. The right to restrict processing: this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
  6. The right to data portability: this gives the Data Subject the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
  7. The right to object: The Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation and direct marketing.
  8. Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.

 

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