The Core Studio (‘the Company’) is committed to protecting the rights and freedoms of data subjects and safely and securely processing their data in accordance with all of our legal obligations. We hold personal data about our employees, workers, volunteers, clients, suppliers and individuals for a variety of business purposes. This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
2. Scope & Eligibility
This policy applies to all employees, workers and volunteers who must make themselves familiar with this policy and comply with its terms. This policy supplements our other policies relating to internet and email use. The Company reserves the right to supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
Who is responsible for this policy?
Our appointed Data Protection Officer (DPO) has overall responsibility for the day-to-day
implementation of this policy. You should contact the DPO for further information about this policy if necessary.
Louise Dupree- Founder and creator
The Core Studio, UK
The purposes of which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
Compliance with our legal, regulatory and corporate governance obligations and good practise.
‘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 identity of that natural person.
Personal data we gather may include: individuals' phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Special Categories of Personal Data
‘Special Categories of Personal Data’ include information about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information — any use of special categories of personal data should be strictly controlled in accordance with this policy.
‘Data Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (the ‘what’, ‘how’ and ‘why’); where the purposes and means of such processing are determined by law.
In our Company, the Data Controller will be Company Founder, Louise Dupree
Data Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller. In our Company, the Data Processor will be its Founder.
‘Processing’ means any operation or set of operations which is performed on personal data or on 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, restriction, erasure or destruction.
This is the national body responsible for data protection. The supervisory authority for the Company is the Information Commissioners Office.
4. The Principles
The Company shall comply with the principles of data protection (‘the Principles’)enumerated in the EU General Data Protection Regulation (GDPR). We will make every effort possible in everything we do to comply with these principles. The Principles are:
First: Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
Second: Limited for its purpose
Data can only be collected for a specific purpose.
Third: Data minimisation
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
Sixth: Integrity and confidentiality
The data we hold must be kept safe and secure.
Accountability and transparency
We must ensure accountability and transparency in all our use of personal data. We must show how we comply with each Principle. You are responsible for keeping a written record of how all the data processing activities you are responsible for comply with each of the Principles. This must be kept up to date and must be approved by the DPO.
To comply with data protection laws and the accountability and transparency Principle, we must demonstrate compliance. You are responsible for understanding your particular responsibilities to ensure we meet the following data protection obligations:
Allowing individuals to monitor processing
5. Our Procedures
5:1 Fair and lawful processing
The Company must process personal data fairly and lawfully in accordance with individuals’rights under the First Principle (see section 4 above). This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening. If the Company cannot apply a lawful basis (explained below), our processing does not conform to the First Principle and will be unlawful. Data Subjects have the right to have any data unlawfully processed erased.
5.2 Controlling vs processing data
The Company is classified as both a Data Controller and a Data Processor (see Definitions in section 3 above). We must maintain our appropriate registration with the Information Commissioners Office (ICO) in order to continue lawfully processing data. As a Data Processor, we must comply with our contractual obligations and act only on the documented instructions of the Data Controller.
As a Data Processor, we must:
Not use a sub-processor without written authorisation of the Data Controller Co-operate fully with ICO or other supervisory authority
Ensure the security of the processing
Keep accurate records of processing activities
Notify the Data Controller of any personal data breaches
If you are in any doubt about how we handle data, contact the DPO for clarification.
5:3 Lawful basis for processing data
The Company must establish a lawful basis for processing data. Ensure that any data you are responsible for managing has a written lawful basis approved by the DPO. It is your responsibility to check the lawful basis for any data you are working with and ensure all of your actions comply the lawful basis. At least one of the following conditions must apply whenever we process personal data:
We hold recent, clear, explicit and defined consent for the individual’s data to be processed for a specific purpose.
The processing is necessary to fulfil or prepare a contract for the individual.
We have a legal obligation to process the data (excluding the contract).
Processing the data is necessary to carry out a public function, a task of public interest or the function has a clear basis in law.
The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest.
5:4 Deciding which condition to rely on
If you are making an assessment of the lawful basis, you must first establish that the processing is necessary. This means the processing must be a targeted, appropriate way of achieving the stated purpose. You cannot rely on a lawful basis if you can reasonable achieve the same purpose by some other means.
Remember that more than one basis may apply, and you should rely on what will best fit the purpose, not what is easiest.
Always consider the following factors and document your answers:
The Company’s commitment to the First Principle requires us to document this process and show that we have considered which lawful basis best applies to each processing purpose, and fully justify these decisions.
We must also ensure that individuals whose data is being processed by us are informed of the lawful basis for processing their data, as well as the intended purpose. This should occur via a Privacy Notice. This applies whether we have collected the data directly from the individual, or from another source. If you are responsible for making an assessment of the lawful basis and implementing the privacy notice for the processing activity, you must have this approved by the DPO.
6. Special Categories of Personal Data
Previously known as sensitive personal data, this means data about an individual which is more sensitive, so requires more protection. This type of data could create more significant risks to a person’s fundamental rights and freedoms, for example by putting them at risk of unlawful discrimination.
The special categories include information about an individual’s:
trade union membership
biometrics (where used for ID purposes) health
cases where we process special categories of personal data, we will require the data
subject's explicit consent to do this unless exceptional circumstances apply, or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
The condition for processing special categories of personal data must comply with the law. If we do not have a lawful basis for processing special categories of data that processing activity must cease.
7:1 Our Responsibilities
7:2 Your Responsibilities
7:3 Responsibilities of Data Protection Officer
7:4 Responsibilities of the IT Manager
7:5 Responsibilities of the Marketing Manager
8. Accuracy & Relevance
The Company will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this. Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.
9. Data Security
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
10.Storing Data Securely
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.
12.Transferring Data Internationally
There are restrictions on international transfers of personal data. You must not transfer personal data abroad, or anywhere else outside of normal rules and procedures without express permission from the DPO.
13.Rights of individuals
Individuals have rights to their data which we must respect and comply with to the best of our ability. We must ensure individuals can exercise their rights in the following ways:
13.1 Right to be informed
13.2 Right of access
13.3 Right to rectification
13.4 Right to erasure
We must delete or remove an individual’s data if requested and there is no compelling reason for its continued processing.
13.5 Right to restrict processing
We must respect the right of an individual to object to data processing based on legitimate interest or the performance of a public interest task.
14. Privacy Notices
14.1 When to supply a privacy notice
A privacy notice must be supplied at the time the data is obtained if obtained directly from the data subject. If the data is not obtained directly from the data subject, the privacy notice must be provided within a reasonable period of having obtained the data, which means within one month.
If the data is being used to communicate with the individual, then the privacy notice must be supplied at the latest when the first communication takes place.
If disclosure to another recipient is envisaged, then the privacy notice must be supplied prior to the data being disclosed.
14.2 What to include in a privacy notice
Privacy Notices must be concise, transparent, intelligible and easily accessible.
The following information must be included in a Privacy Notice to all data subjects:
15 Subject Access Requests
15.1 What is a subject access request?
An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.
15.2 How the company deal with subject access requests
We must provide an individual with a copy of the information the request, free of charge. This must occur without delay, and within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats, and where possible, provide direct access to the information through a remote accessed secure system.
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual must be informed within one month. You must obtain approval from the DPO before extending the deadline.
We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting. This can only be done with express permission from the DPO.
Once a subject access request has been made, you must not change or amend any of the data that has been requested. Doing so is a criminal offence.
15.3 Data Portability requests
We must provide the data requested in a structured, commonly used and machine-readable format. This would normally be a CSV file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to. This must be done free of charge and without delay, and no later than one month. This can be extended to two months for complex or numerous requests, but the individual must be informed of the extension within one month and you must receive express permission from the DPO first.
16 Right to Erasure
16.1 What is the right to Erasure?
Individuals have a right to have their data erased and for processing to cease in the following circumstances:
16.2 How to deal with the right to erasure
We can only refuse to comply with a right to erasure in the following circumstances:
To exercise the right of freedom of expression and information
To comply with a legal obligation for the performance of a public interest task or exercise of official authority
For public health purposes in the public interest
For archiving purposes in the public interest, scientific research, historical research or statistical purposes
The exercise or defence of legal claims
If personal data that needs to be erased has been passed onto other parties or recipients, they must be contacted and informed of their obligation to erase the data. If the individual asks, we must inform them of those recipients.
16.3 The right to object
Individuals have the right to object to their data being used on grounds relating to their particular situation. We must cease processing unless:
16.4 The right to restrict automated profiling or decision making
We may only carry out automated profiling or decision making that has a legal or similarly significant effect on an individual in the following circumstances:
17 Third Parties
17.1 Using third party controllers and processors
As a Data Controller and a Data Processor, the Company must have written contracts in place with any third-party Data Controllers and/or Data Processors that we use. The contract must contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a Data Controller, we must only appoint Data Processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
As a Data Processor, we must only act on the documented instructions of a Data Controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.
Our contracts must comply with the standards set out by the ICO and, where possible, follow the standard contractual clauses which are available. Our contracts with Data Controllers and/or Data Processors must set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
At a minimum, our contracts must include terms that specify:
18 Criminal offence data
Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject. We cannot keep a comprehensive register of criminal offence data. All data relating to criminal offences is considered to be a special category of personal data and must be treated as such. You must have approval from the DPO prior to carrying out a criminal record check.
19 Audits, Monitoring and Training
19.1 Data Audits
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant. You must conduct a regular data audit as defined by the DPO and normal procedures.
Everyone must observe this policy. The DPO has overall responsibility for this policy. The Company will keep this policy under review and amend or change it as required. You must notify the DPO of any breaches of this policy. You must comply with this policy fully and at all times.
You will receive adequate training on provisions of data protection law specific for your role. You must complete all training as requested. If you move role or responsibilities, you are responsible for requesting new data protection training relevant to your new role or responsibilities.
If you require additional training on data protection matters, contact the DPO.
20 Reporting Breaches
Any breach of this policy or of data protection laws must be reported as soon as practically possible. This means as soon as you have become aware of a breach. The Company has a legal obligation to report any data breaches to the DPO within 72 hours.
All staff have an obligation to report actual or potential data protection compliance failures. This allows us to:
21 Failure to Comply
We take compliance with this policy very seriously. Failure to comply puts both you and the Company at risk.
The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.
If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.
22 Data collection types and Process
22.1 Types of information
In addition, we collect the Internet protocol (IP) address used to connect your computer to
the Internet; login; e-mail address; password; computer and connection information and
purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile. We receive, collect and store any information you enter on our website or provide us in any other way.
22.2 How the company collect’s information
The information collected via these processes include but are not limited to;
As a company, restore your core conformation on its clients through processes such as but not limited to;
Conducting transactions on our website (www.restoreyourcore.co.uk) for goods.
Subscribing to our newsletter via the contact sheet on our website.
Sending the company a message via the online contact form.
Contacting the company via email provided on the company website.
Payment details (Credit card information).
When you conduct a transaction on our website, as part of the process, we collect personal
information you give us such as your name, address and email address. Your personal
information will be used for the specific reasons stated above only.
We collect such Non-personal and Personal Information for the following purposes:
22.3 How we store, use, share and disclose our client’s information
Our company is hosted on the godaddy.com platform. Godaddy.com provides us with the online
platform that allows us to sell our products and services to you. Your data may be stored through Godaddy.com’s data storage, databases and the general godaddy.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by godaddy.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
If you don’t want us to process your data anymore, please contact us firstname.lastname@example.org
22:4 The Company’s right to modify
If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact us at email@example.com
23:1 What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner (in this case, Stride) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.
The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):
23:3 How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please
visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
The specific types of first and third party cookies served through our Websites and the purposes they perform are described in the table below (please note that the
specific cookies served may vary depending on the specific Online Properties you visit):
23:4 Essential website cookies
These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.
Service: Country: Type: Expires in:
Provider: Service: Country: Type: Expires in:
Increases website security. It is also a session cookie. www.restoreyourcore.co.uk
Increases website security. It is also a session cookie. www.restoreyourcore.co.uk
23:5 What about other tracking technologies, like web beacons?
Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Websites or opened an e-mail including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
23:6 Do you use Flash cookies or Local Shared Objects?
Websites may also use so-called "Flash Cookies" (also known as Local Shared Objects or "LSOs") to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.
If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the Website
Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).
Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.
23:7 Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.
Where can I get further information?