Shift.ms privacy statement

Contents

     

    1. Introduction

    2. Security

    3. Data that we hold

    4. People who use our website and mobile apps

    5. Sharing personal data

    6. Locations of processing

    7. Individual’s Rights

    8. Complaints

    9. Data Controller and contact information

    10. Changes to our privacy statement

     

    1. Introduction

    Shift.ms (“we”, “us”, or “our”) is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.

    It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

     

    Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

     

    We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

     

    The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).

     

    Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

     

    2. Security

    We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security.

    We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

     

    All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

     

    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 site; 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.

     

    3. Data that we hold

     

    3.1 Members

    We provide services to individuals who use our services.

     

    3.1.1 Why do we process data?

    Where data is collected for professional services, it is used for a number of purposes, as follows;

     

  • Providing our service to members
  • Send members information on matters relating to their membership
  • Improving our website and the services we provide
  • Improving the service by sending emails based on member activity
  • Say thank you for supporting us
  • Produce surveys for you to participate in
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    3.1.2 What data is processed?

    The data that is processed is necessary for the functionality of our service.

     

  • Your username
  • Your email address
  • Your date of birth
  • The country you live in
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    We may gather other information where it’s appropriate, relevant and volunteered, for example:

     

  • Year of diagnosis
  • Type of MS
  • Treatment choice
  • Your closest city
  • Local landmark
  • Social media handles
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    3.1.3 How long do we hold data for?

    We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.

     

    In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

     

    3.2 Our people

    We collect personal data for our people as part of the administration, management and promotion of our business activities.

     

    Our staff handbook and partnership deed explain further how personal data is held for our staff and partners.

     

    3.2.1 Applicants

    Where an individual is applying to work for Shift.ms, personal data is collected through the application process.

     

    There are a number of purposes that personal data for applicants are collected.

     

  • Employment. We process an applicant’s personal data to assess their potential employment at Shift.ms.
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  • Administration and management. We may also use this personal data to make informed management decisions and for administration purposes.
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    Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

     

    4. People who use our website and mobile apps

    When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).

    Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our website, subscribe to our service, make an enquiry, comment on publications, enter a competition, promotion or survey, apply to work for Shift.ms and report a problem with our website.

     

    When individuals visit our website, certain personal data may be automatically collected.
    Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current subscribers. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.

     

    4.1 Why do we process data?

    There are a number of reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

     

  • Functionality. To allow individuals to use some functionality of our website, certain personal data must be entered for features to work as intended.
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  • Security. To keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
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    4.2 What data do we hold?

    The data that we hold depends on what data was entered and for what purpose.

     

    Where data was entered to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

     

    Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

     

    Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

     

    Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

     

    4.3 How long do we hold data for?

    We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

     

    In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

     

    5. Sharing personal data

    We will only share personal data with others when we are legally permitted to do so.

    When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

     

    Personal data held by us may be transferred to:

    Third party organisations that provide applications/functionality, data processing or IT services to us

    We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

    Third party organisations that otherwise assist us in providing goods, services or information

    Law enforcement or regulatory agencies or those required by law or regulations

    Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

     

    6. Locations of processing

    Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA).

    It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

     

    We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

     

    7. Individual’s Rights

     

    Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

     

  • Individuals may request access to their personal data held by us as a data controller.
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  • Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
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  • Individuals may request that we erase their personal data
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  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
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  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
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  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
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  • If you wish to exercise any of these rights, please send an email to [email protected]
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    8. Complaints

    We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to [email protected]

    We will investigate and respond to any complaints we receive.

     

    You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

     

    9. Data Controller and contact information

     

    If you have any questions about this privacy statement or how and why we process personal data, please contact us at [email protected]

     

    10. Changes to our privacy statement

     

    Updates to this privacy statement will appear on this website. This privacy statement was last updated on 17/05/18.