What is GDPR? On May 25th 2018 the General Data Protection Regulation (GDPR) (EU) 2016/679 will come into force. The GDPR is a regulation in EU law on data protection and privacy for all individuals within the European Union and is intended to unify the policies and strengthen the safety and security of all data held within an organisation.
This legislation will replace the existing Data Protection Act (DPA) and is considered the most significant data protection legislation of the last 20 years. There is a plethora of information about the new legislation available online. The Information Commissioner's Office (ICO) provides a good starting point with its Overview of GDPR.
Our compliance Netconsult Online is committed to helping deliver outstanding training for our customers and partners. We have standardised policies and procedures to manage and protect the data that we process on behalf of our company and our partner companies. .
SCOPE All data subjects whose personal data is collected, in line with the requirements of the GDPR by Netconsult Online Ltd by direct communication and the use of Netconsult Online’s registration portal.
RESPONSIBILITIES 2.1 Sales and Operations staff are responsible for ensuring that this notice is made available to data subjects prior to Netconsult Online collecting or processing their personal data. 2.2 All Employees and Staff of Netconsult Online who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured or the legal basis for processing their data has been communicated clearly.
PRIVACY NOTICE 3.1 Who are we? We are Netconsult Online, a training and consulting company who have been trading since 2005. We are authorised as an official training partner by a number of network vendors and as such we manage the registration of end-user and business partner staff on official vendor certification courses we are authorised to run and as such we collect and share personal data with those vendors for engineer and partner training and certification purposes only.
When we refer to ’’we’’, ’’our’’ or ’’Netconsult Online’’ we are referring to Netconsult Online Ltd.
Our Data Protection Officer and data protection representatives can be contacted directly here: • By email: email@example.com • By Mail: Netconsult Online Ltd, PO BOX 257, Chipping Norton, OX7 9BY.
The personal data we may collect or process on you is:
Registered Data Collected
Training Course Attendees Data Subject a) Name (First, Last, Title) b) Company Name c) Business Mailing Address d) Business Email Address e) Business Phone Number & Mobile Number f) Learner ID (If needed) g) Details of training courses attended
Training Course Bookers Data Subject a) Name (First, Last, Title) b) Company Name c) Business Mailing Address d) Business Email Address e) Business Phone Number & Mobile Number f) Details of quotes provided for training courses
Business Partners Data Subject a) Name (First, Last, Title) b) Company Name c) Business Mailing Address d) Business Email Address e) Business Phone Number & Mobile Number
The personal data we collect falls into different categories (sometimes more than one). Your data will be used for the following purposes:
Our legal basis for processing for the personal data:
3.2 Consent of Training Course Attendees Data Subjects By registering for one of our training courses, registering a colleague onto one of our training courses or enquiring about one of our training courses, you are giving us permission to process your personal data specifically for the purposes identified. Consent may be withdrawn at any time by emailing firstname.lastname@example.org Once you have withdrawn your consent your account your personal data will be deleted and/or anonymised within 28 days of your consent being removed.
3.3 Legal basis for processing Training Course Attendee data We are processing your personal data based on Legitimate Interests based on your company’s and/or vendor’s instructions. You may object to this processing by contacting your company or vendor directly. Your company will then work with us to block any future data coming through to our system. We will then remove / anonymise all your personal data on our system within 28 days of the request being made.
3.4 Legal basis for processing Training Course Bookers and Business Partners Data Subjects We are processing your personal data based on implied consent as you contacted us directly either to book a colleague on a training course or you enquired as to the pricing of certification training courses. You may opt out of this processing at any time by contacting us directly at email@example.com. Once you have opted out, we will no longer contact you with information about Netconsult Online products and all of your personal data will be deleted and/or anonymised within 28 days.
3.5 Disclosure In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. Further information is available on request about the factors we shall consider when deciding whether information should be disclosed. You can also get further information on:
Except as set out above Netconsult Online will not pass on your personal data to new third parties without first obtaining your consent. All third parties will have in place agreements consistent with GDPR requirements. We will never sell your data to third parties. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:
Extreme Networks a) Safeguards: USA EU-U.S. and Swiss-U.S. Privacy Shield Framework. b) GDPR Policy: https://www.extremenetworks.com/company/legal/general-data-protection-regulation-gdpr/ c) Purpose: Registration onto training events and providing attendance records and feedback
Hewlett Packard Enterprise a) Safeguards: USA EU-U.S. and Swiss-U.S. Privacy Shield Framework b) GDPR Policy: https://www.hpe.com/us/en/legal/privacy.html c) Purpose: Registration onto training events and providing attendance records and feedback.
Arlo a) Safeguards: USA EU-U.S. and Swiss-U.S. Privacy Shield Framework b) GDPR Policy: https://support.arlo.co/hc/en-gb/sections/360000113523-Data-Protection https://support.arlo.co/hc/en-gb/articles/360000740306-GDPR-EU-Data-Protection-Regulation- c) Purpose: Registration onto training events
3.6 Retention period Netconsult Online will process and store personal data while we are in contact with you with relevant information on our services. If we have not contacted you for a period of 3 years your data will then be removed from our system. If you have opted out to your data being processed we will delete your data within 28 days of your opt out being received.
3.7 Your rights as a data subject At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.5 above) in the processing of your personal data.
3.8 Complaints In the event that you wish to make a complaint about how your personal data is being processed by Netconsult Online (or third parties as described in 3.5 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Netconsult Online’s Data Protection Officer.
The details for each of these contacts are:
Supervisory authority contact details a) Contact Name: Information Commissioner’s Office (ICO) b) Contact Details: https://ico.org.uk/concerns/
Data Protection Officer (DPO) contact details a) Contact Name: Netconsult Online DPO b) Contact Details: firstname.lastname@example.org
How we use your information? This privacy notice tells you how we, Netconsult Online, will collect and use your personal data for (i) supporting the activities of a vendor authorised training partner, (ii) contacting you about key notifications about our training services and (iii) in certain cases sending marketing information about our training services.
Why does Netconsult Online need to collect and store personal data? For training attendees, training bookers and business partners, in order for Netconsult Online to provide those users with our training services, we need to collect and process their personal data for delivering information on training courses to the right person and with the right information.
Will Netconsult Online share my personal data with anyone else? We may pass your personal data on to third-party service providers contracted to Netconsult Online in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to support in delivering our product functionality to our users. When they no longer need your data to fulfil this service, they will dispose of the details in line with Netconsult Online’s procedures. We do not currently process any sensitive personal data, however in the future if this changes and we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Netconsult Online use the personal data it collects about me? Netconsult Online will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Netconsult Online is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Netconsult Online contact me? Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me? At your request, can confirm what information we hold about you and how it is processed. If Netconsult Online does hold personal data about you, you can request the following information: • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU. • Contact details of the data protection officer, where applicable. • The purpose of the processing as well as the legal basis for processing. • If the processing is based on the legitimate interests of Netconsult Online or a third party, information about those interests. • The categories of personal data collected, stored and processed. • Recipient(s) or categories of recipients that the data is/will be disclosed to. • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
How long the data will be stored? • Details of your rights to correct, erase, restrict or object to such processing. • Information about your right to withdraw consent at any time. • How to lodge a complaint with the supervisory authority. • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data. • The source of personal data if it wasn’t collected directly from you. • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this? Netconsult Online accepts the following forms of certified ID when information on your personal data is requested: • Passport • Driving Licence • Birth certificate Once ID has been approved these records will not be retained.
How does Netconsult Online protect my personal data? Netconsult Online are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Does Netconsult Online collect any other information about me? No. Netconsult Online does not collect any other information.