Fair Processing & Privacy Statement
We have always considered ourselves a relationship business, we make connections, we create networking opportunities and we undertake collaborative consultancy & development work with our connections. We have operated this way since 2006 when we formed. We do not advertise.
Maintaining contact through meetings, (virtual and face to face) workshops, newsletters and targeted emails is how we maintain our network.
We are committed to safeguarding the privacy of your personal information and that of our website visitors; this policy sets out how we will treat your personal information.
We retain your personal data to allow us to contact you to tell you about future events, open programmes, meetings, information about the profession and other activity. We may tell you about new services from time to time.
We respect your data and take looking after it seriously. We have clear policies on amendment deletion and we only use it for the purposes described. We respect your privacy rights which are described below. Feel free to contact at any time to ask questions our contact details are at the foot of this statement.
Freedom Consulting Ltd, (Oxen Park is a trading name of Freedom Consulting Ltd) is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). See the foot of notice for full contact details.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
What information do we collect?
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may collect, store and use the following kinds of personal information:
- Identity Data may include your first name, maiden name, last name and title.
- Contact Data may include your billing address, home address, email address and telephone numbers where you provide them to us or they are available in your email signature or footer.
- Financial Data may include your bank account and payment card details where you provide them to us.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your purchases or orders, your feedback and survey responses, your current role and accountabilities either where you provide them to us or obtained from public sources.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect any Sensitive Data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data. We do not collect any information about criminal convictions and offences.
We need to collect the following sensitive data about you in order to deliver the service you purchase from us:
- Your dietary requirements and any relevant health information to assist your access to our programmes should you choose to attend one.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
How we collect your personal data
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services;
- subscribe to our service or publications;
- request resources or marketing be sent to you;
- enter a survey; or
- give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Mouseflow and Google based outside the EU;
- search information providers such as Linkedin based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Eventbrite based outside the EU.
How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver a service to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for our legitimate interests to recover debts owed to us|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests to develop our products/services and grow our business|
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- provided us with your details when you registered for a promotion or free resources; and
- in each case, you have not opted out of receiving that marketing.
We will not share your personal data with any third party for marketing purposes.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- To request access to your personal data and information about our processing of it. You also have the right to request a copy of your personal data (but we will need to remove information about other people).
- To rectify incorrect personal data that we are processing.
- To request that we erase your personal data if:
- we no longer need it;
- we are processing your personal data by consent and you withdraw that consent;
- we no longer have a legitimate ground to process your personal data; or
- we are processing your personal data unlawfully
- To object to our processing if it is by legitimate interest.
- To restrict our processing if it was by legitimate interest.
- To request that your personal data be transferred from us to another company if we were processing your data under a contract or with your consent and the processing is carried out automated means.
- To withdraw consent where we require it for processing your data.
If you want to exercise any of these rights, please contact us at firstname.lastname@example.org.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Third parties who provide our chosen Client Relationship Management software (CRM) where we securely store data.
- Third parties who provide confidential waste disposal services.
- Third parties whose online tools we use to administer our bookings and payments processes for our courses and services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Agents, associates, contributors to events, suppliers or subcontractors insofar as reasonably necessary for the purposes of their role in providing our services to you.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
International data transfers
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Security of your personal information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. The Internet cannot guarantee that email communication is free of viruses, interception or interference and anyone who communicates with us by email is taken to accept the risks in so doing
Downloads and media files
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti-virus software or similar applications.
We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti-virus software or similar applications.
External Website Links and Third parties
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website.
We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
We are registered with the ICO under registration number: ZA342987
We can be contacted at email@example.com, by ringing 01568 797599 or by writing to the Company Secretary at Freedom Consulting Ltd trading as Oxen Park, 3 The Courtyard Bodenham Hereford HR1 3JX