Introduction
City Gateway (“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.
City Gateway may change this policy from time to time by updating this page so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
Any questions regarding this Policy and our privacy practices should be sent by email to diane.betts@citygateway.org.uk or by writing to Data Protection Officer, City Gateway Ltd, Import Building, The Pavilion, 2 Clove Cres, London E14 2BE.
Security
What data is processed?
The data that is processed is dependent on the service that is being provided and on the recipient of this service.
Services to individuals. Personal data may include contact details and medical records, information about courses and event, photographs, videos and any other specifically relevant data.
How long do we hold data for?
We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected, there may also be occasions which will require data to be kept for longer, however this will typically be for legal purposes.
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. We will periodically review this data, to ensure that it is still relevant and necessary.
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.\
Applicants
Where an individual is applying to work for City Gateway, 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 in order to assess their potential employment at City Gateway.
Administration and management. We may also use this personal data in order to make informed management decisions and for administration purposes.
Personal data collected for applicants is held for as long as necessary in order to fulfil the purpose for which it was collected, or for a maximum of one year where those purposes no longer become necessary.
Suppliers
We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide services to our educational participants.
Why do we process data?
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- Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
- Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
- Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:
– managing our relationship with suppliers;
– developing our businesses and services (such as identifying client needs and improvements in service delivery);
– maintaining and using IT systems;
– hosting or facilitating the hosting of events; and
– administering and managing our website and systems and applications. - Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats.
Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes
We take the security of all the data we hold seriously. Relevant 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.
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.
Data that we hold
Personal Data
We provide services to individuals as well as organisations. The exact data held will depend on the services to be provided.
Where we engage with individuals, we may collect and process personal data in order to satisfy a contractual or operational obligation. We request that individuals only provide the personal data that is required for us to fulfil our contractual or operational obligation.
Why do we process data?
Where data is collected for attending our educational programmes, it is used for a number of purposes, as follows;
Providing services to you. Data is processed in accordance with the purpose which we have collected it, and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of educational programmes, the different reason why we may process your data includes;
Individual needs. When communicating with and assessing the needs of clients, personal data may be processed in order to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services are provided to our clients are appropriate.
Administration. In order to manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client-facing applications, and maintaining internal operating processes.
Regulatory. In order for City Gateway to do what it does, we may from time to time be required to collect and process personal data in order to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of the identity of individuals.
The bases on which we process information about you
Contractual obligation: When you create an account on our website or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us
Consent: Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our courses, vacancies and other services, you provide your consent to us to process information that may be personal information.
Legitimate interest: Where we process your information on this basis, we do after having given careful consideration to: whether the same objective could be achieved through other means, whether processing (or not processing) might cause you harm, whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
Legal obligation: We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
People who use our website
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 websites, subscribe to our service, make an enquiry.
For more information, please review our Cookie’s Policy.
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 a 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.
Locations of processing
As part of the services offered to you through this website, the information which you provide to us will not be transferred to the other countries. Right now our servers are based only in the UK.
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.
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.
Individuals may request that we erase their personal data
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.
Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
If you wish to exercise any of these rights, please send an email to City Gateway.
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 City Gateway. We will look into 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
Contact information
Any questions regarding this policy and our privacy practices should be sent by email to diane.betts@citygateway.org.uk or by writing to Data Protection Officer, City Gateway Ltd, Import Building, The Pavilion, 2 Clove Cres, London E14 2BE.
Changes to our privacy statement
Updates to this privacy statement will appear on this website. This privacy statement was last updated on 30/11/2021.
