Website privacy notice
A combination of telephone hacking and other privacy scandals and the publication of the Regulations has completely changed the scenery in the area of privacy law and the expectations of those with whom we deal. The Code tells you what you should and should not be saying in your privacy notice. We find it muddled and unhelpful. The fact is that we all have to comply with the new law but disclosing every cookie by name and location is simply impractical.
We have therefore drawn this very comprehensive document for your use. The ICO clearly do not know how its requirements will unfold, and neither do we. The best we can do is to comply with the law, while recognising that someone, somewhere may find it inadequate.
The document we have provided does not magically absolve you from risk of data mismanagement, but it is a giant first step. A good privacy notice is prime evidence to everyone you deal with and to the ICO, that you take confidentiality seriously.
We have provided a menu of possibilities, use of which depends on the structure of your business and your website. It is not a matter for you to choose what to put into your privacy notice but rather to select items which are relevant or appropriate to your particular business.
This model notice contains 29 options. You will be able to delete some of them. The notice is built around:
• reminding you how to avoid contravening the UK Data Protection Act and the new EU regulations;
• providing re-assurance to your customers or clients;
• maintaining a professional but friendly image.
Of course, the process is itself controlled by a cookie!
This is the privacy notice of Scouting 4 Talent. In this document, “we” or “us” refers to Scouting 4 Talent.
Our registered office is available upon request.
This is a notice to tell you our policy about all information that we record about you. It covers both information that could identify you and information that could not.
We are extremely concerned to protect your privacy and confidentiality. We understand that all users of our web site are quite rightly concerned to know that their data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. Our policy is both specific and strict. It complies with UK law and with the laws of all jurisdictions of which we are aware. If you think our policy falls short of your expectations or that we are failing to abide by our policy, do please tell us.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our web site immediately.
Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected at this site.
Here is a list of the information we collect from you, either through our web site or because you give it to us in some other way, and why it is necessary to collect it:
1. Basic identification and contact information, such as your name and contact details.
This information is used:
1.1. to provide you with the services which you request;
1.2. for verifying your identity for security purposes;
1.3. for marketing our services and products;
1.4. information which does not identify any individual may be used in a general way by us or third parties, to provide class information, for example relating to demographics or usage of a particular page or service.
2. Market place information
When we obtain information from you specifically to enable you to buy a service offered on our web site by some other person, we assume that in giving us your information, you are also giving us permission to pass it to the relevant person.
3. Your domain name and e-mail address are recognised by our servers and the pages that you visit are recorded. We shall not under any circumstances divulge your e-mail address to any person who is not an employee or contractor of ours and who does not need to know, either generally or specifically. This information is used:
3.1. to correspond with you or deal with you as you expect.
3.2. in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our site;
3.3. to send you news about the services to which you have signed up;
3.4. to tell you about other of our services or services of sister web sites.
4. Information you post on our website
Information you send to us by posting to a forum or blog or in your advertisement is stored on our servers. We do not specifically use that information except to allow it to be read, but you will see in our terms and conditions that we reserve a right to use it in any way we decide.
5. Website usage information
6. Financial information relating only to your credit cards
We do not take financial payments.
7. Note on padlock symbols and other trust marks
Many companies offer certification and an icon or other small graphic to prove to site visitors that the site is safe. Some certify to a high level of safety. Others are more concerned to take our money than to provide a useful service. We do not handle information about your credit card so do not subscribe to any such service. However, we suggest you assess this notice to judge that we do take your privacy seriously.
8. Financial information about your direct debit or your credit cards
When you have agreed to set up a direct debit arrangement, the information you have given to us is passed to our own bank [name of bank] for processing according to our instructions. We do / do not keep a copy.
We are registered under the direct debit guarantee scheme. (This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved “originators” of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.)
9. We do not retain any credit card information
10. Credit reference
To assist in combatting fraud, we share information with credit reference agencies so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
11. Business and personal information
This includes all information given to us in the course of your business and ours, such as information you give us in your capacity as our client. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect you to reciprocate this policy.
We keep information which forms part of our business record for a minimum of six years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it.
12. Third party advertising
Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.
13.2. to allow essential parts of our web site to operate for you.
13.3. to operate our content management system.
13.4. to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.
13.5. to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
13.6. to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
13.7. to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.
13.8. to record your activity during a web cast. An example is, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for [three] months, when it will delete automatically.
13.9. to store your personal information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for  days.
13.10. to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube’s privacy-enhanced mode.
14. Calling our help line
When you call our help line, we collect Calling Line Identification (CLI) information. We use this information to help improve the efficiency and effectiveness of our help line
15. Sending a message to our support system
When you send a message, we collect the data you have given to us in that message in order to obtain confirmation that you are entitled to receive the information and to provide to you the information you need. We record your request and our reply in order to increase the efficiency of our business / organisation. We do not keep any personally identifiable information associated with your message, such as your name or email address.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
17. Third party content
Our web site is a publishing medium in that anyone may register and then publish information about himself or some other person. We do not moderate or control what is posted. If you complain about any of the content on our web site, we shall investigate your complaint. If we feel it may be justified, we shall remove it while we investigate. Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content which offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
18. Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
19. Content you provide to us
If you provide information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the World, you have no control whatever as to how it is used.
20. Marketing information
With your permission we pass your email address and name to selected associates whom we consider may provide services or products you would find useful. You may opt out of this service at any time by instructing us at [URL]
21. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.
22. Affiliate information
This is information given to us by you in your capacity as an affiliate of us or a customer or client of ours. Such information is retained for business use only. We undertake to preserve the confidentiality of the information and of the terms of our relationship. It is not used for any other purpose. We expect any affiliate to agree to reciprocate this policy. As an exception to this, we have the right to disclose your first name and URL of your affiliate connection to other affiliates and to any other person or organisation, on and off site. The reason is solely to enable us to mention winners and others whose performance as an affiliate is in some way outstanding.
23. Use of site by children
We do not market to children, nor do we sell products or services for purchase by children. We do sell products and services for end use by children, but for purchase by adults. If you are under 13, you may use our site only with consent from a parent or guardian.
24. Use of site by children
Certain areas of our website are designed for use by children over 13 years of age. These areas include [description or name or areas designed for children]. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
AND / OR
25. Use of site by children
If you are under 13, you may use our site only with consent from a parent or guardian.
26. Disclosure to Government and their agencies. We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
27. At any time you may review or update the personally identifiable information that we hold about you, by contacting us at the address below. To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.
28. Sale of your personal information
Except as specified above, we do not rent, sell or otherwise disclose any of your information to any person outside our business.
29. Data may be “processed” outside the UK
Our web sites are hosted in the UK We also use outsourced services in countries outside the EU from time to time in other aspects of our business. Specifically, our technical centre is based in Newcastle upon Tyne. Accordingly data obtained within the UK may be “processed” outside the UK and data obtained in any other country may be processed within or outside that country.
30. Compliance with the law
This confidentiality policy has been compiled so as to comply with the law of every jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your country, we should like to hear from you, but ultimately it is your choice as to whether you wish to use our website.
31. Removal of your information
If you wish us to remove personally identifiable information from our web site, you may contact us at http://www.scouting4talent.com/contact-us/To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.
Now take me back where I was before reading this.
Website privacy notice
Notes referable to specific numbered paragraphs
1 Basic identification and contact information
This is information collected by most web sites. What you do with it is obvious but including it here completes the picture.
2 Market place information
To use if you take orders on your web site for a third party.
3 Your domain name and e-mail address
This is information collected by most web sites. Basic and obvious.
4 Information you post on our website
This is an area often omitted from suggested text, but it may be important. The fact that someone posts insensitive or forbidden or stupid information does not give you a licence to use it without care. However, well drawn terms and conditions will make clear that contractually you have a licence to use any such information as you decide.
5 Website usage information
This information is unlikely to be personally identifiable.
6 Financial information relating only to your credit cards
In this and the following paragraphs we have given you several alternatives. Select the one that most accurately reflects the way you do business.
7 Note on padlock symbol and trust marks
We have added this because we ourselves have been asked from time to time whether our site is “safe” since we do not show any such mark. Leave it or delete it.
8 Financial information relating only to direct debits or your credit cards
Provides for direct debit arrangements and explains in plain English how they work.
9 We retain your credit card information securely
Edit the five sub paragraphs to reflect how you really do protect your financial information.
10 Credit reference
We suggest that you leave this paragraph in place even if you have no immediate intention of liaising with debt collectors. It may be a useful reminder to users of your web site.
11 Business and personal information
Amidst the noise about privacy we have to remember that we also have legal obligations to keep business financial records
12 Third party advertising
This is a simple statement of the obvious. In practice, the demons that appear in our systems are usually cookies of some sort, placed by these third parties, often with the connivance of the webmaster of a site based far away.
14 to 28 We have no comment on these paragraphs. Select which apply to you.
29 Data may be “processed” outside the UK
It is important that this information is disclosed to comply with the law.
End of notes
All documents are copyright Net Lawman Ltd. Documents may be enlarged, reduced or otherwise edited, but we ask you please to keep the copyright notice in place so far as that does not inconvenience your use of the document. If you want to remove it, then you may do so.