How 2040 uses data about you
There isn’t a cookie banner asking for your consent because the 2040 website only uses essential cookies. That’s the plan, anyway, but I recently had the site tidied up and WordPress has a nasty habit of dropping things in and turning things on. If you encounter any non-essential cookie (i.e. one that is not related to security or to delivering a service that you as a website user want), let me know. I don’t want these things running, and I’ll happily turn off anything and everything tracking-related.
It’s a bit sad that I felt I had to put this first, but the Data Protection world seems to think that cookies are the most important thing that exists, so here we are.
The controller for personal data processed via this website and to deliver 2040 Training services is 2040 Training Limited, a company registered in England (Company No: 6682698). For all practical purposes, 2040 Training is in fact Tim Turner. I don’t have any staff, it’s just me. 2040 Training Limited is registered with the Information Commissioner’s Office, but this means absolutely nothing beyond the fact that I have to give them £35 a year. It is in no way an illustration of good practice or sound data handling.
The purposes for which data relating to you will be used will depend why you contacted me. Personal data will be processed according to my legitimate business interests, except for limited storage of data for legal purposes which is outlined below (essentially for tax purposes).
Mailing list: the purpose of processing your data is to send you a limited number of emails promoting 2040 training courses and other products. It will never be shared with any other data controller and will be deleted if 2040 Training is shut down or sold. I use Mailjey
FOI Five: your email address will be used to send you the FOI newsletter once a month. It will not be used for any other purpose. It will be deleted if 2040 Training is shut down or sold
Enquiries: if you contact me about a course or generally ask a question, your data will be processed solely to deal with whatever you contacted me about.
Booking and running training courses: data will be processed to deliver courses in line with your booking, invoice you and chase debts if you do not pay your invoice. Please pay your invoice.
Blocklist: people and the organisations they represent who do not pay will be put on a blocklist. The blocklist will be used to ensure than any future bookings from those people / organisations will be cancelled immediately. The list will not be shared with any other organisation or used for any other purpose.
Disclosures and other purposes
If you contact 2040, you will not be added to the 2040 mailing list unless you actively opt-in to do so. You can opt out at any time.Your data will not be passed to any other controllers or individuals in the normal course of business, apart from the company’s accountants (see below). If circumstances arise where your data might be shared with a third party for any reason beyond tax purposes, 2040 Training will contact you directly.
You might be asked to provide a reference or testimonial, but you can ignore this request.
Transfers + processors
Your data will be stored in the UK except where it is used by one of the below processors.
I use Mailjet to run my mailing list & FOI Five newsletter – your data will be transferred to the EU (Belgium).
I run public courses using GoToWebinar – your data will be transferred to the US and possibly Australia.
There is no alternative to this so if you do not wish these organisations to process your data, you can’t be on the lists or attend these courses.
Your data will not be retained after any work is completed and any invoices are paid, unless you consent to do so, or 2040 has a legal obligation to retain the data. This is likely to involve your name to be retained for seven years for tax purposes, if your name features on any invoices or purchase orders.
Emails and other correspondence are purged after one year. Invoices or other data with your name on will be accessed by 2040’s accountant for the purposes of paying tax and other legal requirements, but the data will not be used by them for any other purposes.
You can exercise any of your data protection rights to 2040 Training.
Your rights over personal data *that relates to you* are as follows:
- a right of access to personal data held by or on behalf of 2040 Training Limited. Note that this applies to personal data processed for the purposes of 2040 Training Limited, and not to personal data processed by Tim Turner in a personal, domestic or private capacity. 2040 Training only makes use of public social media posts to promote its products and services.
- a right to rectify any personal data held by 2040 Training Limited that you believe is incorrect
- a right to erase any personal data that 2040 Training Limited no longer has a legitimate purpose to process
- a right of access to a machine readable version of personal data that you provided to the company or that 2040 Training Limited has observed it via your use of a service. This is only applicable to data provided with your consent or under a contract, but I will endeavour to give you a portable version of any of personal data that relates to you should time and technology allow.
- a right to stop 2040 Training Limited processing any personal data relating to you that it does not have a legal or contractual obligation to process
- a right to prevent any wholly automated decisions involving personal data – I do not use any wholly automated decision-making techniques
To exercise any of these rights, please contact email@example.com.
2040 Training does not satisfy the GDPR requirement to appoint a Data Protection Officer, so it does not have one.
You will need to prove your identity before getting access to data that relates to you or exercising your other rights. This may be achieved by providing a proof of ID (which will not be retained) or by providing contextual information that proves that you are who you say you are.
If you have any concerns about 2040’s handling of personal data that relates to you, you can raise these with me directly, but you have a right to make a complaint to the Information Commissioner. See their website: www.ico.org.uk
And as you got all the way to the end, here’s a picture of a squirrel: