Your privacy: our General Data Protection Regulation compliance statement
This is a statement of the General Data Protection Regulation compliance policy that is adopted by Business Owners Direct Limited (BODL) for delivering our services, which include offering businesses for sale, and recommending trusted partners for legal and insurance services.
(BODL) will, when delivering these services, collect and use personal information only which is relevant to the services that we are offering and which will be controlled, stored and processed in accordance with the General Data Protection Regulations (GDPR), howsoever it is collected, recorded and used; whether it be on paper, in electronic media form (e.g. in a computer system), or recorded by other means.
We consider the lawful and correct treatment of personal information by the company as critical in maintaining the confidence of our users and clients; we therefore manage and process personal information lawfully and correctly.
Information is defined under the GDPR as being Personal Information if any of the following criteria are met:
- Can a living individual be identified from the data, or, from the data and other information in the possession of, or likely to come into the possession of, the data controller?
- Does the data “relate to” the identifiable living individual, whether in their personal or family life, business or profession?
- Is the data “obviously about” a particular individual?
- Is the data “linked to” an individual so that it provides particular information about that individual?
- Is the data used, or is it to be used, to inform or influence actions or decisions affecting an identifiable individual?
- Does the data have any biographical significance in relation to the individual?
- Does the data focus or concentrate on the individual as its central theme rather than on some other person, or some object, transaction or event?
- Does the data impact or have the potential to impact on an individual, whether in a personal, family, business or professional capacity?
We adhere to the Principles of Data Protection, as set out in the Data Protection Act 2018 and the General Data Protection Regulations (GDPR), which came into force in May 2018.
Specifically, these Principles require that personal information:
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met.
- Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
- Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
- Shall be accurate and, where necessary, kept up to date.
- Shall not be kept for longer than is necessary for that purpose or those purposes.
- Shall be processed in accordance with the rights of data subjects under the Act.
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
(BODL) will, through appropriate management and by strict application of criteria and controls:
- Observe fully the conditions regarding the fair collection and use of information.
- Meet its legal obligations to specify the purposes for which information is used.
- Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements.
- Ensure that the quality and accuracy of information used is adequate and is maintained.
- Apply strict checks to determine the length of time information is held and that it is stored for no longer than is necessary.
- Ensure that the rights of people about whom information is held are able to be fully exercised under the Act and Regulations.
- These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information.
- Take appropriate technical and organisational security measures to safeguard personal information.
- Ensure that personal information is not transferred abroad to countries to which transfers are not permitted under the GDPR.
- There is an officer appointed with specific responsibility for data protection within the company: You may contact our Data Protection Officer by via e-mail at firstname.lastname@example.org.
- Everyone handling, managing and working with personal information understands that they are contractually and legally responsible for following the GDPR and good data protection practice.
- Everyone handling, managing and working with personal information is appropriately trained to do so.
- Everyone handling, managing and working with personal information is appropriately supervised.
- Anyone wanting to make enquiries about personal information knows how to do so.
- Queries about personal information are promptly and courteously dealt with, in accordance with the GDPR.
- Methods of handling, managing and working with personal information are clearly described.
- A regular review and audit is made of the way personal information is managed.
- Methods of handling, managing and working with personal information are regularly reviewed, assessed and evaluated.
- The performance of the methods and process is regularly reviewed, assessed and evaluated.
Information processing – general
We do not undertake automated decision making about, or profiling of personal data.
Data subjects have a right, as set out in the GDPR, to obtain the personal information which is stored and used by us, and can obtain this information by contacting the Data Protection Officer whose details are given in this document. The data comprising the personal information will be delivered to the data subject in a secure manner and in a format which is readily accessible using common proprietary data access tools (such as word processor document or spreadsheet viewer programs).
GDPR compliant policy for enforcement information
What information do we obtain, process and/or store:
We receive basic personal information relating to both the sale of your business, your contact details and the contact details of any potential purchaser.
The personal information which is obtained consists of name, address(es) telephone contact details.
What we use the data we collect for:
The information which we obtain, store and process is necessary and is used to enable us to market your instruction.
We confirm that no part of our enquiry will be sub-contracted to any other person or company without prior client. No information concerning the data subject given to us by our clients or obtained during the course of business will be used for any other purpose. At all stages of the process we act as a data controller and as such we will fully comply with the GDPR and with the Data Protection Act and its guiding principles.
What we use the data we collect for:
We use the data collected relating to the tracing subject’s address to appraise our client of the subject’s current residential and/or commercial address and/or telephone number and/or e-mail address.
Once the tracing operation has been completed, we normally retain the detailed information recording the tracing activity for 6 years, in accordance with the Limitation Act 1980. We are able, upon request of the data subject, to securely erase all personal data stored for the purpose of tracing. At no stage will we divulge to a third party any personal data.
Whatever the instruction, we confirm that no part of our enquiry will be sub-contracted to any other agent without prior client approval. We also confirm that no information concerning the data subject given to us by our clients or obtained during the course of a trace enquiry will be used for any other purpose.
At all stages of enquiries we recognise that we are acting as our clients’ data processor and as such we will fully comply with the GDPR and with the Data Protection Act and its guiding principles.
GDPR compliant policy for marketing and general information
What information we collect:
We acquire and use the information you upload relating to the sale of your business for marketing purposes.
Our clients provide this information directly, when uploading an instruction to act on their behalf.
We also obtain information by recording how persons use our websites by means of embedded technology such as cookies, and by receiving written enquiries and usage data from relevant forms hosted on our website.
Calls to our telephone system may be recorded and Calling Line Identity (CLI) numbers are identified and stored where they are not withheld.
We also obtain data from third parties.
We protect data obtained from third parties according to the practices described in this statement, together with any additional restrictions that are imposed by the source of the data. These third-party sources vary over time, but have included:
- Data brokers from whom we purchase demographic data.
- Service providers that help us determine a location based upon your IP address.
- Partners with whom we offer co-branded services or engage in joint marketing activities.
- Publicly-available sources such as open government databases or other data in the public domain.
If you are requested by us to provide your personal data, you may of course decline to do so. However, if you do choose not to provide data that is necessary to enable us to provide a service to you (e.g. the sale of your business), we may not be able to deliver that service to you.
The information that we obtain may be dependent upon the nature and context of your enquiry or instruction. The information that we collect can include the following:
Name and contact data. We collect your first and last name, postal address, phone number and e-mail address.
Demographic data. We may on occasion collect data about you such as your profession, country and preferred language.
Contacts and relationships. We may collect such information that you provide us relating to your contacts and business relationships from online surveys.
Location data. Our on-line services may obtain imprecise location data: e.g. a location derived from your IP address or data, that indicates where you are located with low precision, such as at a city or postcode level.
Content. We may collect the content of any data files and communications that you may send us in the course of an instruction, together with any physical documents that you may give us when these are necessary to provide you with the service you have purchased. Data we collect may include:
- the address, subject line and body of an email,
- text or other content of an instant message,
- audio and video recording of a video message or attachment, and
- audio recording and transcript of a telephone call or voice message you send to us or receive from us.
What we use the data we collect for:
We use the data that we collect to operate our business and to deliver the services that we provide, to send communications, including marketing promotional materials, and to deliver advertising of our services.
Service delivery. We use information which we collect to provide and to improve the services which we offer and to undertake essential business operations. This includes service delivery and monitoring, maintaining and improving the quality standards, security and performance of our services, developing new services, conducting research and providing focused advice to our clients. Examples of such uses include the following:
Communications. We use information which we collect to communicate with our clients and with their staff, and thus to and personalise our communications. We may contact you by telephone or by e-mail or other means to inform you when a publication or presentation which may be of professional interest is available or to inquire or to advise about a service enquiry that you have made, or to invite you to participate in a survey or to attend a commercial event. For information about how to manage, edit or to delete contact data which contains your personal information, please use the contact and access section of this privacy statement.
Advertising. We may use personal information contained in e-mail, telephone calls or voicemail, or your documents, or data files to target advertisements to you. We do not share any data which we collect with third parties. The advertisements that you see on our interactive media may be targeted based upon information stored, such as IP address.
Data retention. For advertising and marketing, we retain data for no longer than 48 months, unless we obtain your consent to retain the data for a longer period
How to access & control your personal data:
You can submit a request to view, edit or delete any personal data that we hold and which is not retained for the purpose of selling you business.
You may do so by submitting a request in writing or by using our Contact Us form. We will respond to requests to access or delete your personal data within 30 days.
Your marketing choices
You may opt out of receiving marketing information by using our Contact Us form , or by un-subscribing using the link incorporated into all our e-mail communication.
Because the data used for marketing may also be used for other necessary purposes (for example if you have instructed us to enforce a writ or collect monies owing), in such cases, opting out of marketing does not stop that data from being collected or stored.
Changes to this privacy statement
We will update this privacy statement when necessary to reflect customer feedback and changes in our services. When we post changes to this statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement or in how we will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how we are protecting your information.
How to contact us
If you have a privacy concern, complaint or a question for the Data Protection Officer, please contact us by using our online Contact page. We will respond to questions or concerns within 30 days. Unless otherwise stated, (BODL) is a data controller for personal data we collect through the products and services subject to this statement
Business Owners Direct Limited September 2020