Privacy Policy

The Purpose of this privacy statement is to explain how Embrace North Norfolk Limited processes all personal data to fulfil its data protection responsibilities. This statement will be supplemented by ‘specific to client’ privacy notices when needed. Brief definitions of data protection, personal data and processing can be found at the end of this statement.

The scope of this statement covers all related activities by the staff of Embrace North Norfolk Limited.

The Role of Embrace North Norfolk Limited in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the Embrace North Norfolk Limited privacy manager (PM) to ensure that it is processed in accordance with the latest UK and EU data protection legislation.

The PM can be contacted by email at claire@embracenn.com.

The sort of personal data processed by Embrace North Norfolk Limited will only be basic contact information for the purposes of replying to general enquiries.

Embrace North Norfolk Limited’s duty of confidentiality means that Embrace North Norfolk Limited staff will treat client and employee data with due respect and in confidence. It is only disclosed to staff that need to know it. Embrace North Norfolk Limited uses reasonable organisational and technical measures to ensure personal data is kept secure.

Embrace North Norfolk Limited also expects the same duty of confidentiality of all third parties with whom it shares personal data, including contractors. Sharing is kept to a minimum and reviewed regularly.

Embrace North Norfolk Limited processes personal data against a lawful basis and such instances are described below:

• To respond to your general enquiries, we will use our legitimate interests;
• To comply with any legal obligation;
• When it is necessary for the performance of a contract and its prior preparation; and
• When processing a pre-defined purpose for which your consent has been sought and recorded prior to that processing commencing.

In all cases the processing of personal data by Embrace North Norfolk Limited shall be:

• Processed fairly, lawfully and transparently;
• Collected for specified, explicit and legitimate purposes;
• Adequate, relevant and limited to what is necessary (and no more);
• Accurate and, when necessary, updated;
• Kept for no longer than is necessary; and
• Processed in a manner that ensures appropriate security.

Embrace North Norfolk Limited will share personal data, but only when absolutely necessary, with some or all of the following third parties:

• Solicitors appointed by Embrace North Norfolk Limited;
• The Inland Revenue (HMRC);
• Contractors, but only on a strict need to know basis;
• Accountants appointed by Embrace North Norfolk Limited and only for accounting purposes; and
• Unspecified recipients but only when compelled to do so for legal reasons.

Embrace North Norfolk Limited will process your data in different places but mostly within the European Economic Area (EEA). First line personal data processing takes place in the UK, but it is backed up using reputable cloud service providers in the USA. Email is processed using a reputable web-based provider and mobile phone contacts are stored on both office IT equipment and mobile phones. The latter are backed up to Apple iCloud and/or Google. It should be noted that no personal data is stored on any of Embrace North Norfolk Limited’s website servers.

Embrace North Norfolk Limited safeguards all business and personal data in encrypted form, in so far that it is possible. Other than mobile phone contact data, all data in automated form is backed up with a cloud service provider certified to the ISO 27001 Information Security Management System (ISMS) standard.

Embrace North Norfolk Limited follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:

• Routine correspondence for casual and contract related business in hard copy or in emails will be stored for 3 years;
• Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject;
• Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing; and
• By exception, documentation that includes personal data may be retained by Embrace North Norfolk Limited beyond the schedule, but only for a specific purpose and only when Embrace North Norfolk Limited believes there is a legitimate interest or a legal obligation to do so.

At the end of the retention schedule Embrace North Norfolk Limited will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that Embrace North Norfolk Limited allows up to 2 months after the retention schedule to complete the action.

Embrace North Norfolk Limited websites may link to appropriate websites for our interest. If these are used, the visitor should be aware that the Embrace North Norfolk Limited has no responsibility for the control, content or handling of personal data by these other websites.

The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:

• Right to be informed as to how your personal data is being processed by Embrace North Norfolk Limited – this is done through this statement or separate Embrace North Norfolk Limited privacy notices;
• Right to access your personal data held by Embrace North Norfolk Limited which is done by making a ‘Data Subject Access Request’ (DSAR) to the Embrace North Norfolk Limited privacy manager;
• Right to rectification of your personal data if you believe Embrace North Norfolk Limited has collected it incorrectly or it needs to be updated;
• Right to erasure of your personal data for which Embrace North Norfolk Limited no longer has a legitimate purpose to process;
• Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved;
• Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract;
• Right to object to Embrace North Norfolk Limited processing your personal data for which it does not have a legal or contractual obligation;
• Rights related to automated decision making and profiling (however Embrace North Norfolk Limited does not use these techniques in its decision making);

Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk.

Raising concerns, exercising rights or making queries about Embrace North Norfolk Limited’s processing of personal data can be done by

• Contacting the Embrace North Norfolk Limited privacy manager. Please be aware that Embrace North Norfolk Limited will need to determine your identity before responding fully, therefore, you may be asked for proof of ID or other material that, in context, will enable Embrace North Norfolk Limited to confirm your identity; or
• Contacting the relevant Supervisory Authority. In the UK this is the ICO.

What data protection, personal data and processing means

The term data protection, put simply, means the protection of personal data against misuse and abuse. Personal data means any information relating to an identified or identifiable natural person, also referred to as a ‘data subject’. Processing has a very wide interpretation and means any operation which is performed on personal data or on sets of personal data whether or not by automated means. This includes, inter alia, collection, recording, storage, adaptation, retrieval, actual use, dissemination or otherwise making available, restricting, erasure or destruction.