1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights.
- We have a duty of care to the people whose data we collect.
- Data should only be collected and processed when absolutely necessary.
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information.
2.0 RELEVANT LEGISLATION
Our business and internal computer systems, and our website, are designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
Our business’s compliance with the above legislation, all of which are stringent in nature, means that our website, our processes and systems are likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether Dysguise Ltd is compliant with your own country of residence’s specific data protection and user privacy legislation, you should contact our data protection officer (details of whom can be found in section 8.0 for clarification).
3.0 PERSONAL INFORMATION THAT WE COLLECT, AND WHY WE COLLECT IT
3.0.1 Assessment data
The legal basis for us processing your personal data is the contract that we have with you. We also need to process your data before we have a contract with you. The legal basis for processing your data before the contract is the legitimate interest that we have in providing you with assessment services.
To provide you with our services, we need to collect personal information, (such as your name and date of birth), contact details (such as your phone number), information about significant events in your life, education history health details and assessment scores. We collect this information so that we can communicate with you in a personal way, provide you with assessments for learning difficulties, and process your payments for our services. If you are not prepared for us to process your data, it will not be possible to provide you with our assessment services.
Our website collects and uses personal information for the following reasons:
3.0.2 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use these data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address. This could be used to personally identify you, but Google do not grant us access to this. We consider Google to be a third-party data processor (see section 4.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.0.3 Contact forms and email links
Should you choose to contact us using the contact form on our ‘Contact us’ page or an email link, none of the data that you supply will be stored by this website or passed to/be processed by any of the third-party data processors defined in section 4. Instead, the data will be collated into an email and sent to us. All emails retained on our server are encrypted.
3.1 DATA STORAGE
We keep your information in the stores described below:
3.1.1 On our company computers
We use personal computers that are located on our business premises, and we use laptop computers when out of the office. All computers are password-protected, and the hard drives are encrypted. Passwords are changed every 90 days, and it is company policy that passwords are not shared. We use Dropbox to store your data. If you send us personal information in an enquiry, and an assessment is then arranged, the procedures for processing your data are noted below. If an assessment is not arranged, we keep your information for 90 days and then delete it.
3.1.2 Your customer record
We use Microsoft Excel, which is a computer program that stores administrative information in the form of a table. The Excel file is stored on Dropbox. The customer record includes the date of your assessment, the associated fee, and it notes information relating to the date of request(s) for payment, and the date of receipt of payment. Information on our customer record is kept for three years from the date of the assessment.
3.1.3 Your assessment and report
We carry out some of the assessment using Pearson’s Q-interactive platform. This is protected by 2-Factor Authentication (2FA). Test scores generated by the Q-interactive platform are used in your assessment report. Once the report is written, we delete test scores from the Q-interactive system.
We create an electronic report that contains all the information that we gather, and our findings and conclusions. This is generated using our bespoke, web-based reports programme. The company that supports the programme software has stated that they are compliant with GDPR. When the report is completed, it is downloaded and stored in Dropbox. The electronic copy of your report is kept for three years from the date of your assessment.
3.1.4 As a paper copy
We take hand written notes when we meet you. These notes are used to create the report that we provide to you. These notes are kept with hard copies of the assessment papers and summary scores. Assessment notes are stored in archive boxes in our office. Assessment notes are kept for three years from the date of your assessment, and after this they are shredded.
4.0 RECIPIENTS OF YOUR DATA (INCLUDING THIRD-PARTY DATA PROCESSORS)
We send your report to you and/or to anyone you have consented to be provided with a copy of your report, and to anyone we are required by law to inform. All reports that are sent electronically are sent as attachments that are encrypted and password- protected.
Our accountant is given the information needed to raise an invoice, and this is done by using a shared Dropbox folder. The accountant is based in the UK, and all their computer systems are in the UK.
We send the details about your access to our website to our web analytics provider (see section 3.1). They are based in the US.
5.0 YOUR RIGHTS
5.1 How can I see all the information you have about me?
You can make a Subject Access Request (SAR) by contacting the Data Protection Officer. We may require additional verification that you are who you say you are to process this request.
We may withhold such personal information to the extent permitted by law. In practice, this means that we may not provide information if we consider that providing the information will violate your vital interests or the vital interests of other parties.
The diagram below shows our process flow for a Subject Access Request:
5.2 What if my information is incorrect?
Please contact the Data Protection Officer. We may require additional verification that you are who you say you are to process this request.
If you wish to have your information corrected, you must provide us with the correct data. We will locate the computer file (stored in Dropbox) that contains the final pdf of your report, and the final Word document that was used to create the pdf. Both documents will be amended as appropriate.
After we have corrected the data in our systems, we will send you a copy of the updated information in the same format as the subject access request in section 4.1.
5.3 How can I have my information removed?
If you want to have your data removed, we have to determine if we need to keep the data – for example, in case HMRC wish to inspect our records. If we decide that we should delete the data, we will do so without undue delay.
5.4 Referral to a supervisory authority
Should you be unhappy with the way we process your personal data, you have the right to lodge a complaint with the ICO (Information Commissioner’s Office).
6.0 DATA BREACHES
We will report any unlawful data breach to any and all relevant persons and authorities within 72 hours of us becoming aware of the breach.
The diagram below shows our data breach procedure:
The data controller of this website is: Dysguise Ltd, a UK Limited Company with company number: SCO 384856 whose registered office is:
8 Dean Bank Lane
8.0 DATA PROTECTION OFFICER
Dr Jennie Guise
Director, Dysguise Ltd
Telephone: (0131) 629 8269