Privacy Policy – Outsource Typing

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, transcription workers and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, transcription workers and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.5 In this policy, “we”, “us” and “our” refers to Fiona Frame, Data Controller, Outsource Typing. For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data“). The account data may include name, postal address, telephone number and email address. The source of the account data is you or your employer/client. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.5 We may process personal data that is provided in the course of the use of our services (“service data“). The service data may include name, date of birth, postal address, telephone number and email address. The source of the service data is you or your employer/client. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is legitimate interest.

3.8 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.11 We may process information contained in our recruitment processes (“transcription worker data”). This data may include typical information commonly contained within a CV, such as full name, telephone number, postal address, date of birth, marital status and previous work history. The source of this data is from our existing and current transcription workers, previous applicants/previous transcription workers and applicants with data to be kept on file for matching with future appropriate opportunities that arise from time to time in our business. This data may be processed for record keeping. The legal basis for this processing is consent.

3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the proper administration and running of our business services. All subcontracted staff are bound by our Acceptance Agreement which has strict provision for confidentiality and data handling.

4.4 Financial transactions relating to our website and services are handled by our payment services providers, PayPal and Woocommerce. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices for PayPal at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full and Woocommerce here https://woocommerce.com/usage-tracking/.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 Currently, we have offices and facilities in the United Kingdom only. The European Commission has made an “adequacy decision” with respect to the data protection laws of other countries. Transfers to any of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

5.3 Currently, the hosting facilities for our website are situated in the United Kingdom only. The European Commission has made an “adequacy decision” with respect to the data protection laws of other countries. Transfers to these will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

5.4 Currently, our transcription workers (who provide subcontracted administrative, typing and transcription services) are situated in the United Kingdom only. The European Commission has made an “adequacy decision” with respect to the data protection laws of other countries. Transfers to these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Usage data will be retained for a minimum period of 48 hours following your visit to our website, and for a maximum period of 2 years following your visit to our website.

(b) Account data will be retained for a minimum of 48 month following any enquiry, and for an indefinite period until such services are terminated either by you or by us.

(c) Profile data will be retained for a minimum of 48 hours following any visit to our website, and a maximum period of 2 years following your visit to our website.

(d) Service data will be retained for a minimum of 48 hours following any enquiry, and for an indefinite period until such services are terminated either by you or by us.

(e) Publication data will be retained for an indefinite period of time, until any request is made for the removal of the information from our website.

(f) Enquiry data will be retained for a minimum of 48 hours following any enquiry, and for an indefinite period until any request is made for removal of the information from our possession.

(g) Transaction data will be retained for a minimum of 48 hours following any enquiry and a maximum period of 5 years.

(h) Notification data will be retained for a minimum of 48 hours following any enquiry and for an indefinite period until any request is made for removal of the information from our possession.

(i) Correspondence data will be retained for a minimum of 48 hours following any enquiry and for an indefinite period until any request is made for removal of the information from our possession.

(j) Transcription worker data will be retained for a minimum of 1 month following any enquiry and for an indefinite period until any request is made for removal of the information from our possession.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of account data will be determined based on our continued working relationship. Should this be terminated by either you or us the data will be removed.

(b) the period of retention of service data will be determined based on based on our continued working relationship. Should this be terminated by either you or us the data will be removed.

(c) the period of retention of publication data will be determined based on whether or not it provides value to visitors to our website.

(d) the period of retention of enquiry data will be determined based on on the usefulness to you in terms of future service provision.

(e) the period of retention of correspondence data will be determined based on usefulness to you in terms of future service provision.

(f) the period of retention of transcription worker data will be determined based on the usefulness to either party in terms of future opportunities within our business.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or persons.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email.

8. Your rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at GBP £10); and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank, plus an original copy of a utility bill showing your current address).

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose can be found here);

(b) status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose can be found here);

(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose can be found here);

(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose can be found here);

(e) advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose can be found here);

(f) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose can be found here); and

(g) cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally (cookies used for this purpose can be found here).

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies can be found here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

You can opt out of Google Analytics tracking your information by visiting this link to their add-on services https://tools.google.com/dlpage/gaoptout

11.3 We use Facebook to allow social sharing. Facebook may use cookies on your computer when you use their service. You can view the privacy policy of this service provider at https://www.facebook.com/about/privacy/

11.4 We use Twitter to allow social sharing. Twitter may use cookies on your computer when you use their service. You can view the privacy policy of this service provider at https://twitter.com/en/privacy

11.5 We use LinkedIn to allow social sharing. LinkedIn may use cookies on your computer when you use their service. You can view the privacy policy of this service provider at https://www.linkedin.com/legal/privacy-policy

11.6 We use Woocommerce to allow us to provide products to purchase in our website’s shop. Woocommerce may use cookies on your computer when you use their service. You can view the privacy policy of this service provider at https://docs.woocommerce.com/document/woocommerce-security-faq/

11.7 We use PayPal to accept payments from customers in our website’s shop. PayPal may use cookies on your computer when you use their service. You can view the privacy policy of this provider at https://www.paypal.com/en/webapps/mpp/ua/privacy-full

11.8 We use WordPress as a platform or our website. WordPress may use cookies on your computer when you use this service. You can view the privacy policy of this provider at https://en-gb.wordpress.org/about/privacy/

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Fiona Frame, Outsource Typing.

13.2 Our principal place of business is at 3 Main Street, East Saltoun, East Lothian, EH34 5DZ.

13.3 You can contact us:

(a) by post, to the postal address given above;

(b) by telephone, on the contact number published on our website from time to time; or

14. Data protection officer

14.1 Our data protection officer’s contact details are: Fiona Frame, 3 Main Street, East Saltoun, East Lothian, EH34 5DZ Tel: 01875 340 892.

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