How 2040 uses your data

Updated 3rd August 2021 (Hi, how are you?)

Personal data is processed on the basis of 2040 Training’s legitimate interest in making money. The processing of client personal data is minimal and will not be used for any purpose beyond carrying out requested work or sending newsletters. Some data will be retained under the legal obligation to pay UK taxes if personal data appears on invoices. Please indicate if you do not wish personal data to appear on invoices.

The purposes for which your data will be used will depend why you contacted 2040.

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.

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.

Enquiries: if you contact me about a course or ask a question, your data will be processed solely to deal with whatever you contacted me about.

Booking and running training courses: your 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.

COOKIES: There isn’t a cookie banner because the 2040 website doesn’t use cookies – indeed, a famous cookie expert personally assured me that no cookies were used on this site. There is some weird Google font nonsense at work because of the WordPress Theme I am using, but I am working on having these expunged.

Blocklist: people who fail to pay will be put on a blocklist. The blocklist will be used to ensure than any future bookings from those people will be cancelled immediately. The list will not be shared with any other organisation or used for any other purpose. You will be informed directly if you are placed on the blocklist. There is no procedure to be removed, as I have a legitimate interest in avoiding future work with people who don’t pay.

If you contact 2040, you will not be added to the 2040 mailing list unless you actively ask 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.

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.

I use Mailjet to run my mailing list & FOI Five newsletter. I run public courses using GoToWebinar. There is no alternative to this so if you do not wish these organisations to process your data, I am afraid that you can’t be on the lists or attend these courses.

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.

Your data will be stored in the UK except where it is used by one of the above processors.

You can exercise any of your data protection rights to 2040 Training.

Your rights are:
  • a right of access to your personal data held by or on behalf of 2040
  • a right to rectify any personal data held by 2040 that you believe is incorrect
  • a right to erase any personal data that 2040 no longer has a legitimate purpose to process
  • a right of access to a machine readable version of your data, as long as you have provided it or 2040 has observed it via your use of a service. This is only applicable to data provided with your consent or under a contract, but we will endeavour to give you a portable version of any of your data should time and technology allow
  • a right to stop 2040 processing any of your data that it does not have a legal or contractual obligation to process
  • a right to prevent any wholly automated decisions involving your data. 2040 does not use any wholly automated decision-making techniques
To exercise any of these rights, please contact

2040 Training does not meet 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 your data 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 your personal data, you can raise these with Tim Turner directly, but you have a right to make a complaint to the Information Commissioner. See their website:

And as you got all the way to the end, here’s a picture of a squirrel: