Privacy Policy

Phase 8 Change (P8C) respects your privacy and is committed to protection, security, fair and transparent processing of your personal data. This privacy notice outlines the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and will also tell you about your privacy rights and how the law protects you. This privacy notice relates to our processing of personal data of past, present and prospective clients of P8C and such other third parties who interact with us (including visitors to our website).

1 – Who we are

Phase 8 Change Ltd (Company number 11340645) registered in England and Wales with their registered offices being at 3 Kelvin Grove, Chester, Cheshire, CH2 2EL, and collectively referred to as “P8C”, “we”, “us” or “our” in this Policy).

We have appointed a designated data privacy team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy team using the following details:

Email address: info@phase8change.co.uk
Postal address: Phase 8 Change Ltd, 3 Kelvin Grove, Chester, CheshireCH2 2EL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We may change this privacy notice from time to time. Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. This version was last updated on 11th September 2023.

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.

2 – The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you depending on the nature of services we are providing. We have grouped together the types of personal data as follows:

• Identity Data includes name.
• Contact Data includes email address, telephone numbers.
• Financial Data includes bank account details.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Usage Data includes information about how you use Our Sites (as defined below) and our services.

We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We DO NOY process sensitive personal data (as defined within the UK data protection act).

In the event that we are required to process sensitive data, this will only be done under the protections of a commercial agreement with all relevant contractual obligations and protections included.

The services which we provide together with Our Sites are not intended for children and we do not knowingly collect any data relating to children.

If you fail to provide personal data

Where we need to collect personal data by law, or in order to perform the services for you and you fail to provide that data when requested, we may not be able to provide you with the services however we will notify you if this is the case at the time.

3 – How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in and submitting “Contact Us” forms on our website (“Our Site”) or by corresponding with us in person or by post, phone, email, social media or otherwise. This includes personal data you provide.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.

Information collected from you about other people

When you provide personal information to us which does not relate directly to you but is personal information of a third party (for example, details of your customers, or staff members), you confirm that you are authorised to do so and shall ensure that this privacy notice is brought to the attention of such individuals so that those individuals understand how their data will be used by us. We will hold and use such personal information in accordance with this privacy notice and data protection laws.

In addition, the sharing of this type of 3rd party data will always be covered by either a data sharing agreement, or a contract, contain all necessary security and privacy provisions.

Third-party links

Our Sites may include links to third-party websites, specifically relating to clients we have worked with in the past. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our Sites, we encourage you to read the privacy notice of every website you visit.

4 – How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• For the delivery of a contracted service.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

We DO NOT use your information for automated decision making.

Generally, we do not rely on consent as a legal basis for processing your personal data except in those circumstances set out in the table below relating to sending direct marketing communications via email or as otherwise set out in this privacy notice. You have the right to withdraw consent to marketing at any time by following the links on any marketing message sent to you or by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Slide right to see full table as required

We have set out below further information on the meaning of each of the legal bases for processing set out in the third column of the table above:

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to provide the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Consent means processing your personal data where you have provided a freely given, specific, informed and unambiguous indication of your agreement to us processing your personal data.
• Contract: Where we have entered into a form contract to provide services to you/your organisation, we will process data under the protections of this contract. All processing will be limited to the scope, objectives, and timeframe of the contract.
• Opting out: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
• Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
• Change of purpose: 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.

5 – Disclosures of your personal data

We will never share your personal information, or any other information provided to us by you with any other organisation, with the exception that we are required to do so by law.

Should we identify a possible product or service offered by a partnership organisation which you may benefit from, we will only provide your information to these organisations with explicit consent from yourself.

6 – International transfers

We may need to send your personal data outside of the EEA. Where your personal data is being transferred outside the EEA, we will carry out an assessment of the level of protection required taking into account the circumstances relating to the transfer. We may, in certain circumstances, need to obtain your consent to the transfer unless there is an overriding legal need to transfer the personal data.

7 – Data 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. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

8 – Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.

Furthermore, in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9 – Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You 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. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

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

No fee usually required

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 may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.