How 2040 uses data about people
Who is this?
2040 Training Limited, a company registered in England (Company No: 6682698) is the controller for personal data processed via this website and to deliver all services and products. In practice, dealing with 2040 means working with Tim Turner.
Purposes + lawful basis
I use personal data for my legitimate business interests of selling training and consultancy. The exception is when I have to keep data for tax purposes, which is a legal obligation.
Enquiries: if you contact me about a course or ask a question, I will only use data that identifies you to deal with whatever you asked me about.
Booking and running training courses: I will use the minimum necessary personal data to deliver courses, to invoice you and to chase you if you do not pay your invoice. Please pay your invoice. I do not need to know the names of attendees unless you think it will help, but it is likely that I will see such data on in-house events. I will not use any data obtained during in-house events for any other purpose without the individual’s consent.
Blocklist: I put the names of direct contacts who do not pay or whose organisations do not pay onto a blocklist. I use this blocklist to prevent any future bookings from those people / organisations. The list will not be shared with any other organisation or used for any other purpose. There is no appeal process unless you pay what you owe.
Promo: I will ask you for feedback, and I might ask you to provide a reference or testimonial. You can ignore this.
The lawful basis for all of the above is my legitimate interests in running the company for profit.
Mailing list: If you consent, I will send you a monthly email promoting 2040 courses and products with your consent. There are no trackers on the emails.
FOI Five / Daily / jobs email: If you consent, I will use your email address to send you the email of your choice. There are no trackers on the emails.
You can withdraw your consent at any time.
Third parties + International transfers
Data about 2040 clients / subscribers / enquirers will be stored in the UK except where it is used by one of the below organisations.
My accountants are Daawie and Mitha – they hold data for 2040’s tax purposes but they have their own legal obligations should an audit or legal issue arise. There is no need for personal data to be stored on an invoice so please minimise what you provide when booking.
I use Mailjet to store all mailing lists and send all emails – your data will be transferred to the EU (Belgium). If you’re unhappy with providing personal data to Mailjet but want to sign up, contact me.
I run public courses using GoToWebinar – your data will be transferred to the US and Australia.
If you pay by credit card, I use Stripe – your data will be transferred to their servers in Europe and the US. You will be subject to their policies if your name is associated with the card that you use.
For both of the above, I rely on the fact that it is contractually necessary to transfer data to these locations on an occasional basis in order for you to pay and attend courses.
All these organisations have their own legal obligations and should be considered to be data controllers in their own right. I am keen to provide anonymisation options where possible, including registering for a course using an anonymous email account. You must pay upfront if you want to do this. Anonymity is impossible for payments unless you have a corporate credit card or a bank account that has no personal data associated with it.
I keep data about clients until work is completed and any invoices are paid, unless 2040 has a legal obligation to retain the data. This will only be for tax purposes.
I keep data about current subscribers to 2040 emails and newsletters via Mailjet. I also use Mailjet to keep the details of anyone who unsubscribes to suppress their details. If you unsubscribe and then change your mind, email me to work it out.
2040 and its accountants will keep invoices for seven years for legal tax purposes.
I delete all emails and any other correspondence after one year.
UK GDPR gives you rights over personal data *that relates to you*. You can do the following:
- you can access personal data held by or on behalf of 2040 Training Limited. Please note the difference between 2040 Training the company and Tim Turner the individual. They are not the same.
- you can correct any personal data held by 2040 Training Limited if you can show it is incorrect
- you can ask me to erase any personal data that 2040 Training Limited no longer has a legitimate purpose to process
- you can get a machine readable copy of personal data that you provided to 2040 Training Limited or that was observed via your use of a 2040 service. This is only applicable to data provided with your consent or under a contract.
- you can stop 2040 Training Limited from processing any personal data relating to you that the company does not have a legal or contractual obligation to process. You can opt out of anything else I send you whenever you like
To exercise any of these rights, please contact me at firstname.lastname@example.org. If you think I am using personal data about you in any way that is unfair or prejudicial to you, I will fix it if I can.
You may need to prove your identity before getting access to data that relates to you or exercising other rights. This may be by showing me a proof of ID or by providing contextual information that proves that you are who you say you are.
If you have any concerns about my handling of personal data that relates to you, you can raise these with me directly. You have a right to make a complaint to the Information Commissioner. See their website: www.ico.org.uk