Privacy Policy

This website privacy policy was updated on 16 July 2020.

Key details

Hassell Inclusion Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We understand how important online privacy is, especially in this day and age. We want to assure you that we take your online privacy seriously.

The following describes how we handle data provided to us by visitors to this website. If you are asked to provide information when using this website, it will only be used in the ways described in this privacy policy.

We may change this policy from time to time so please check this page occasionally to ensure that you’re happy with any changes.

If you have any questions about this policy, please email privacy@hassellinclusion.com or write to us by post at Hassell Inclusion, 205 Wrotham Rd, Gravesend, Kent DA11 7LE, UK.

Introduction

Like many other websites, hassellinclusion.com captures analytics data that helps us understand some basic information about traffic to this website, including when, from where and how often traffic flows to this site.

Some of the information we capture is anonymous (we cannot identify you from this information). In the case of information provided by visitors who sign up to be sent our blogs when we post them, or information on our book, we capture more specific information that allows us to send information to you, which does identify you.

What personal data we collect and why we collect it

Contact form

If you use our contact form, we collect the data in the form: your name, phone and email address. We use this data to contact you in response to your specific enquiry.  We may also use your email for marketing purposes which may include contacting you with news and offers on our products and services. The legal basis for collecting and using this data is that it is in our legitimate interests to do so for the purposes responding to your enquiry, and sharing the latest accessibility news and details of our business.

Newsletter Terms & Conditions

If you sign up for our newsletter, we use the data in the form: your email address. We will only ever use your email address to share the latest accessibility news and details of our business and charitable activities. It’s easy to unsubscribe and we will never share your details with anyone else. The legal basis upon which we are relying in collecting and using your data in this case is that you have given your consent.

Webinar Terms & Conditions

If you sign up for our webinars, we use the data in the registration form for the purposes of the administration of the booking and communication with you regarding the webinar and its provision. We may also use your email for marketing purposes which may include contacting you with news and offers on our products and services. We will add your email to our Newsletter list. It’s easy to unsubscribe and we will never share your details with anyone else. The session will be video-recorded by the hosts, for the purpose of internal data analysis and reporting only. An automated transcript service to provide captions for those with hearing difficulties will be available during the sessions. The legal basis for collecting and using this data is that it is in our legitimate interests to do so for the purposes of administering and providing the webinar, and sharing the latest accessibility news and details of our business.

Public Training Terms & Conditions

If you sign up for our public training courses, we use the data in the registration form for the purposes of the administration of the booking and communication with you regarding the training course, the provision of the course, and the administration of the pre-course and post-course assessments. We will not share your details with third parties for marketing purposes.  The legal basis for collecting and using this data is that it is in our legitimate interests to do so for the purposes of administering and providing our training.

Snapshot Audit Terms & Conditions

If you sign up for a snapshot audit, we use the data in the registration form for the purposes of the administration of the booking and communication with you regarding the audit, the provision of the audit, and the administration of the pre-audit information. We will not share your details with third parties for marketing purposes.  The legal basis for collecting and using this data is that it is in our legitimate interests to do so for the purposes of administering and providing our audits.

Scorecard Terms & Conditions

If you fill in our Scorecard, we use the data in the registration form for the purposes of providing a score of your accessibility maturity and personalising the report we email you. We may also use your email and mobile number for marketing purposes which may include contacting you with news and offers on our products and services. We will add your email to our Newsletter list. It’s easy to unsubscribe and we will never share your details with anyone else. The legal basis for collecting and using this data is that it is in our legitimate interests to do so for the purposes of administering and providing the scorecard, and sharing the latest accessibility news and details of our business.

Comments

If you leave a comment on our site we collect the data shown in the comments form, and also your IP address and browser user agent string to help spam detection. The legal basis for collecting this data is that it is in our legitimate interests to do so for the purposes administering our website.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available at: https://automattic.com/privacy/ (external site). After approval of your comment, your profile picture is visible to the public in the context of your comment.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

We do not control these third-party websites and are not responsible for their privacy statements, which we encourage you to read.

Analytics

We may also collect the following analytics data to help us present timely and relevant information to our visitors:

• Internet Protocol addresses (IP)
• Types of browser
• Internet Service Provider (ISP)
• Date and time stamp
• Referring and exit pages
• Number of clicks

The legal basis for collecting and using this data is our legitimate interest in administering our website.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Cookies

Cookies are small files placed on your computer’s hard drive. Cookies enable our website to identify your computer as you view different pages on hassellinclusion.com.

We may use cookies to:

• If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
• Analyse our web traffic using an analytics package such as Google Analytics. Aggregated usage data helps us improve our website structure, design, and content.
• Test content on our website

Please note: cookies do not provide us with access to your computer or any information about you other than that which you choose to share with us.

You can use your web browser’s cookie setting to determine how our website uses cookies. If you do not want our website to store cookies on your computer or mobile device, you should set your web browser to refuse cookies.

To learn more about cookies and how they are used, visit http://www.allaboutcookies.org (external site)

How long we retain your data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Subject to the above, we would normally retain your personal data in accordance with the following:

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

We will retain the data collected:

• when you sign up for our newsletter or webinar, until you opt out of receiving the newsletter, except where we are legitimately retaining your data for another purpose;
• when you sign up for public training, for 3 years after the training has been completed (in case you want to undertake further training);
• when you sign up for a snapshot audit, for 3 years after the audit has been completed (in case you want further services);
• when you fill in our scorecard, for 3 years after the scorecard is completed;
• when you leave a comment, the comment will remain indefinitely unless you ask us to remove it

What rights you have over your data

Under certain circumstances, you have the following rights under data protection law in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Further details of these rights are set out in at the end of this policy.

If you wish to exercise any of the rights set out above, please contact us using the details below.

We also require your consent to use your information for marketing purposes, but you can easily change your mind by:

• Sending us an email to privacy@hassellinclusion.com
• Writing to us at Hassell Inclusion, 205 Wrotham Rd, Gravesend, Kent DA11 7LE, UK
• Or by calling us by telephone on 0208 106 1186

If you have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Upon request of deletion of your information our procedure is to identify and delete all information held by us. These sources may include password-protected databases, secure cloud storage servers, and secure email.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If for any reason you are unhappy with the way that Hassell Inclusion has processed your personal information deletion request, you have the right to lodge a complaint with a supervisory authority. See https://www.gov.uk/data-protection/make-a-complaint (external site)

Where we send your data

We may share your personal data with the parties set out below for the purposes set outagainst that party:

• Dropbox – for storing your data
• Microsoft – for administering and storing your data, and for contacting you;

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we transfer your personal data outside the European Economic Area (EEA) we will make sure you are given the same level of technical and legal protection as you are within the EEA through Model Contract Clauses approved by the EC, US Privacy Shield or other approved mechanism.

Visitor comments may be checked through an automated spam detection service.

We will never lease, distribute or sell your personal information to third parties unless we have your express permission or the law requires us to. Furthermore, to prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Additional information

Any personal information you give us is stored and processed under our Data Protection policies, in line with the General Data Protection Regulation (GDPR) and Data Protection Act 2018.

We keep our privacy policy under regular review. This version was last updated in March 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Children’s Privacy

Our Services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from young people under 18. In case we discover that a young person under 18 has provided us with personal information, we will immediately delete this information from our records. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we are able to take all necessary action.

Your Legal Rights

You may have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.