1. Definitions and Interpretation In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means R G Wilbrey (Consultants) Limited, a limited company registered in England under company number No 797081, whose registered address is Aspen House, Great Brickkiln Street, Wolverhampton, West Midlands, WV3 0PT.
2. Information About Us
2.1 Our Site is owned and operated by R G Wilbrey (Consultants) a limited company registered in England under company number 797081, whose registered address is Aspen House, Great Brickkiln Street, Wolverhampton, West Midlands, WV3 0PT.
2.2 Our VAT number is 100573909.
2.3 Our GDPR points of contact are Pam Ward – Client & Supplier/Louise Farlow – HR & Training Delegate related data protection, and can be contacted by email at [email protected] or [email protected], by telephone on 01902 420920, or by post at Aspen House, Great Brickkiln Street, Wolverhampton, West Midlands, WV3 0PT.
2.4 We are regulated by NEBOSH, HIGHFIELDS, CSKILLS, IOSH & UKATA for some of our training courses
2.5 We are a member of BHSEA and a number of our advisors are Members of IOSH and OSHCR registered
2.6 We are ISO 9001:2015 certified by Interface Limited, an accredited certification body, who carry out an annual audit to ensure compliance.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about our collection and use of personal data;
4.1.2 The right of access to the personal data we hold about you (see section 8);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);
4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 15);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 15 and We will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.1 Depending upon your use of our Site, we may collect some or all of the following personal and non-personal] data:
- business/company name
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, address and service required;
- Company registration number
- Special Data – any special data you may feel applicable (please contact our training
- department with regard to our learner personal data procedure & Delegate consent
- form – Special data
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security, see section
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- Supplying our services to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring our services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing your request to [email protected]),
- Market research
- Emailing or sending documentation relating to our contracted services.
6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR post with information, news, and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Chat information will be retained for 1 month after which time it will be deleted.
- Chat enquiries will be passed to the relevant departments, and personal data will bekept by each department as defined in our Company Retention Policy.
7. Sensitive Personal Data
7.1 In addition to the basic data described above, it may also benefit you to notify us when enrolling as a delegate of any health condition or disability you have, so that we are aware of these conditions and how they affect you. This will allow us to take any reasonable steps to accommodate specific needs or requirements you have when providing our services to you. This type of information is known under the law as ‘special category information’ (you may also know this as ‘sensitive personal data’) and we require your explicit consent to process this information.
7.2 This kind of information will only be collected from you and used by R G Wilbrey (Consultants) Limited to assist you, it will not be shared with any third parties and will only be kept as long as it is required for this purpose, or until such time as you notify us you no longer consent to it being held or processed by us.
8. How we collect data about you and your use of this website
You are in control of what information we collect about you. We may ask for information about you when you use our “Chat” facility or when you request brochures or other information. We may also invite you to complete surveys or provide us with feedback.
9. How and Where Do We Store Your Data?
9.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
9.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
9.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.
9.4 Steps we take to secure and protect your data include:
In cases where personal data is being processed by third parties, a rigorous adequacy process is being performed to ensure that your data is always secured.
- Web applications of R G Wilbrey (Consultants) Limited. are operated in ISO 27001 certified secure data centres in the UK.
- Firewalls, anti-virus and anti-malware and backup and disaster recovery is in place to prevent data loss or deletion.
- Closed circuit television and door access control to authorised personnel secures the office.
- Access to infrastructure, elevated privileges and network are granted on an as-needed basis.
- Infrastructure and web applications operated by R G Wilbrey (Consultants) Limited is backed up on a regular basis and business continuity and disaster recovery is tested on a regular basis.
- Ensuring all Company IT equipment & mobile phones are password protected
- All paperwork containing personal data no longer required is shredded or burnt.
- Ensure all our employees, clients & suppliers are aware of our Data Protection Policies
- Ensure all employees have received training with regard to GDPR
We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. Do We Share Your Data?
10.1 Subject to section 10.2, we will not share any of your data with any third parties for any purposes.
10.2 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
10.3 We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, Associate Health & Safety services AND/OR our Accredited Training Providers. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
10.4 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
10.5 The third party data processors used by us are located inside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
11. What Happens If Our Business Changes Hands?
11.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
12. How Can You Control Your Data?
12.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
12.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13. Your Right to Withhold Information
You may access our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
14. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details using the contact details below in section 13. Alternatively, please refer to our Data Protection Policy, which is available upon request.
15. Contacting Us
Additional Contact Details: R G Wilbrey (Consultants) Limited Aspen House Great Brickkiln Street Wolverhampton WV3 0PT
Telephone: 01902 420920
Like many websites, this website uses a technology called ‘cookies’, which are small computer files that are placed in your computer’s memory by the computer that provides or ‘hosts’ the website. Cookies are used to track data such as the total number of visits to the website. We use this information, which remains in aggregate form, to understand how our visitors use this website, so that we may improve the services we offer.
They help us to improve our website and to deliver a better service. Some of the cookies we use are essential for the website to operate. R G Wilbrey (Consultants) Limited does not use ‘cookies’ to collect personal identity information about you.
What is in a cookie?
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or whether you are logged into a site to protect your privacy.
What to do if you do not want cookies to be set:
Some people find the idea of a website storing any information on their computer or mobile device intrusive, particularly when this information is stored and used by a third party without their knowledge. Although R G Wilbrey Consultants Limited cookies are quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some cookies, all cookies, or even cookies that have already been set; but you need to be aware that you might lose some functions of the website.
Web browser cookies
If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.
Strictly necessary cookies
Some cookies are strictly necessary in order to enable you to move around the website and use its features. Without these cookies, we will not be able to determine the number of unique users of the site or provide certain features.
Details of our Cookie usage:
WHAT THE COOKIE IS USED FOR & DETAILS
WHAT TYPE OF COOKIE?
Recognising you as a return visitor
Using analytics software and a cookie, we can tell that you’ve visited the RGW website, which helps us understand what parts of the site you’re coming back to see.
Monitoring website traffic and video traffic.
We want to know which parts of our site are popular and which parts are putting you to sleep, so we use a cookie to analyse traffic as it moves around the RGW website.
First-Party (including Google) and Third-Party
Reminding you of RG Wilbrey elsewhere
Many third parties such as weblogs, newspapers, search engines and other sites online will use a cookie to check if you’ve visited the RGW website lately, as part of a service that we use. If you have visited us, the third party will show you an advertising message on their website.
Third-Party (including Google)
Understanding how people found us
We want to know how our website caught your eye, so we use a cookie to understand how you found the RG Wilbrey website when you visit.
Third-Party (including Google)
Offering a live chat facility
If you have a question about the RG Wilbrey website, we can quickly answer it using a live chat on the website. We use a cookie to remember whether you closed the live chat box so we won’t show it again.
First-Party / Third Party
Any queries regarding this policy should be directed to our GDPR Point of Contact:
Pam Ward Quality Manager
Email [email protected] ,
Telephone: 01902 420920
This version was updated on 16th May 2018