Verlander Walker Ltd GDPR and Privacy Statement

Verlander Walker Ltd promises to respect your personal data and to keep it safe. We intend to be clear when we collect your data and to not do anything you wouldn’t reasonably expect. There are systems and processes in place to protect your data and to ensure that you aren’t bothered by communications from us that you do not want.

This GDPR and privacy statement tells you how we look after your personal data, where we get it from, and your privacy rights and how the law protects you.

Who we are
What data we collect
How we collect your data
How we use your data
Keeping your data safe
Who we share your data with
How long we keep your data
How we use cookies
Your rights
Further information

1. Who are we?

Penny Walker is the trading name of Verlander Walker Ltd. Verlander Walker Ltd is registered with the Information Commissioners Office.

The Data Protection Officer (DPO) is Penny Walker. If you have any questions about this GDPR and privacy statement, or a request to exercise your legal rights, please contact Penny:

Verlander Walker Ltd

Penny Walker

92 Winston Road, London, N16 9LR

020 7254 3500

penny@penny-walker.co.uk

You have a legal right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisory authority for data processing issues in the UK. There is more on their website www.ico.org.uk We would be really glad if you contact us first with any concerns, so we can sort them out fast and directly.

We want to make sure that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at penny@penny-walker.co.uk

2. What data we collect

We only collect data that is relevant to the matter that we are dealing with. In particular, we may collect the following data from you which is defined as ‘personal data’:

personal details (e.g. name, address, email, phone number, employer or organisational affiliation);
financial and transaction details (where you have paid us, or we have paid you); and
professional or community activities and interests.

(i) Data we may process, as a result of professional and community interactions.

If you are a client, potential client, peer, collaborator, potential collaborator, trainee, participant in a workshop or attendee at a meeting or similar, records may exist which contain your personal data. These may include, but are not limited to:

email and other contact details;
a record of your signing up for, being invited to, or attending a particular meeting, workshop, course or other event;
a record of you being a speaker, presenter, facilitator or in some other way a member of the organising and delivery team of an event;
a record of your responses, contributions or feedback to formal or informal requests for your perspective or opinions (in line with any ground rules about attribution or confidentiality agreed for the process or meeting);
copies of email exchanges related to the professional interaction;
or contributions to collaborative platforms (including but not limited to comments on blog posts on www.penny-walker.co.uk/blog, google docs, Trello, Basecamp, Facebook conversations, LinkedIn posts and LinkedIn group conversations);
flip chart or other paper-based records of conversations.

These records exist in order to help us deliver a service to you (if you are a client) or because the business has a legitimate interest in making and keeping them.

(ii) Special categories of data

From time to time, special categories of data may be collected and processed, if shared by you in the course of an assignment such as coaching or stakeholder engagement.

‘Special categories’ of personal data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Such information is not pro-actively sought or routinely collected, however if you share such information as part of a coaching session, peer learning, training, consultation or stakeholder engagement workshop, the information may be collected or processed. It will only be collected and processed in line with any agreements about confidentiality and attribution already agreed in the ground rules of the assignment.

3. How we collect your data

(i) Direct interactions

You may provide data by filling in forms on our site (or other sites such as when booking an event via Eventbrite or filling in a survey on SurveyMonkey) or by communicating with us by post, phone, email, video conference, in person or otherwise, including when you:

contact us about services, products, projects, assignments , workshops, courses or other professional or community matters.
order our products or services;
sign up to receive mailings, newsletters or updates; See section 4(ii) below.
Exchange contact details at events, workshops, seminars, conferences or networking events, or via online platforms such as Twitter, LinkedIn or Facebook
request resources or marketing be sent to you;
contact me asking for advice, guidance, support or to connect;
enter a competition, prize draw, promotion or survey; or
give us feedback.

(ii) publicly available sources such as Twitter, LinkedIn or Facebook or your own website.

(iii) we automatically collect information in the form of cookies, when you visit our website www.penny-walker.co.uk (see section 8 below on cookies).

4. How we use your data

We will only use your data where we’re allowed to by law, e.g. carrying out an agreement we have with you, fulfilling a legal obligation, because we have a legitimate business interest or where you agree to it.

(i) summary of different ways your data may be used

(ii) Newsletter, updates, mailing list

If you sign up to receive mailings, updates or newsletters, we will use your contact details to, from time to time, send you newsletters, updates or information about topics including:

facilitation, group dynamics, collaboration, convening, dialogue, stakeholder engagement, coaching and related ‘process’ topics;
organisational and system change, being a change agent, being a better sustainability professional;
events, courses, workshops, training, publications and blog posts related to these, written by or delivered by Penny Walker;
events, information, news and insights from others, about these topics, that we think you may be interested in.

If you sign up to receive updates, mailings or newsletters, you can unsubscribe at any time.

Signing up to receive such mailings, updates or newsletters is separate from working with us for example as a client, sub-contractor, peer, trainee or workshop participant. Unsubscribing from the newsletter or mailing list will not preclude us working together in any of these ways and will not mean that we no longer keep details about our work together or other professional contact we may have had. See section 9 below for your rights in relation to this other data.

(iii) other uses

Verlander Walker Ltd does not:

offer services to children;
utilise automated decision-making;
operate in circumstances which might lead to a DPIA being necessary.

(iv) 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.

5. Keeping your data safe

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. We limit access to your personal date to those agents, contractors and other third parties who have a business need to know. These security measures include:

Confidential paper waste is shredded before being sent for recycling.
Data is routinely backed up to both physical and remote backups. The cloud-based back-up is covered by GDPR.
Mobile devices are password protected and / or encrypted.
The office is in a secure building.
Certain paper records, which are covered by GDPR, are kept in a locked filing cabinet in the office.
Financial transactions are processed using platforms and software which are secure and themselves covered by GDPR. This may include, but is not limited to: FreeAgent, Eventbrite, PayPal, Cooperative Bank.

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

6. Who we share your data with

We will never sell your data to a third party for marketing purposes. If we need to share your data with another company in order to provide you with a service (for example, a sub-contractor who is managing bookings for a workshop or producing a report or record of a workshop) we will do so in a way that is secure and GDPR compliant.

We may have to share your personal data with certain third parties (see the list below for examples). Where your data is shared, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Service providers, acting as processors, who provide IT and system administration services,
Professional advisers, acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide book-keeping, consultancy, banking, legal, insurance and accounting services,
Sub-contractors or partner organisations acting as processors or joint controllers e.g. support facilitators, who are working as part of the delivery team on projects.
HM & Customs, regulators and other authorities, acting as processors or joint controllers, who require reporting or processing activities in certain circumstances.

Our website contains links to other websites run by other organisations. This privacy policy applies to www.penny-walker.co.uk and we are not responsible for the privacy policies and practices of other sites even if you access them using links from our website.

7. How long we keep your data

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 (including our legitimate interest in building long-term relationships with colleagues, peers, clients, stakeholders and potential collaborators) and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see section 9 below for further information.

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.

8. How we use cookies

We use cookies to understand how visitors are using our website. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, remember you when you visit again, and this helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can set your browser not to accept cookies. Disabling cookies in your browser may mean you are not able to access all or parts of the site. The information collected by cookies is non-personal and allows us to statistically monitor how people are using our website.

9. Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

You can see more about these rights at: ICO.

If you would like us to remove you from our mailing, update or newsletter list (see section 4(ii) above) entirely, let us know and we will remove the information you ask us to. We may retain your name on a ‘suppression’ list to ensure you are not contacted inadvertently.

If you would like to view any or all of the data we may hold on you, please ask us.

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 further information in relation to your request to speed up our response.

We aim to comply with all data requests within one month of having confirmed your identity. Occasionally it may take us longer 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.

10. Further information

If you have any questions about how any of this affects you, please get in touch: penny@penny-walker.co.uk or 020 7254 3500.

This version was last updated in May 2018.