OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people whose data we hold and manage
- Data should only be collected and processed when absolutely necessary
- We will never sell, rent or otherwise distribute or make public your personal information
- We loathe spam as much as you do!
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- Privacy and Electronic Communications (EC Directive) Regulations 2003
- EU General Data Protection Regulation 2018 (GDPR)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9) for clarification.
PERSONAL INFORMATION THIS WEBSITE COLLECTS – HOW AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Cookies & site visitation tracking
A cookie is a small piece of data that our website asks your browser to store on your computer or mobile device. Generally, it contains certain information that is not personally identifiable to you, but is used to improve and personalise your web experience. For example, a cookie can include the date and time of visits to the website, the sites visited just before and just after it, the pages viewed, and the time spent on the website.
Our system will automatically create cookies when you visit our website. Cookies are not necessary for the use of our Website, so you can block or disable them by configuring your browser to allow you to block the installation of some or all cookies. Almost all browsers allow you to be alerted to the presence of cookies or block them automatically. If you block cookies, you can continue to use our website, although some services may be limited and you may not experience the full functionality of our website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6 below).
In addition to Google Analytics, this website may collect information attributed to the IP address of the computer or device that is being used to access it. The information is supplied to us by Zoho SalesIQ from Zoho Corporation Pvt. Ltd (Zoho). We consider Zoho to be a third party data processor (see section 6.0 below). If you are unknown to us, Zoho SalesIQ does not use your IP address to identify you, the individual, in any way. If you are already known to us as a contact within our Zoho CRM system, Zoho SalesIQ may be able to identify you as a returning web visitor.
3.2 Our blog
Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website.
Your comment and its associated personal data will remain on this site until we see fit to either remove the comment or remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us here using the email address that you used to comment with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information in the actual comment field of any blog post comments that you submit on this website.
3.3 Contact form, web forms & email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to/be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Zoho Corporation Pvt. Ltd (Zoho) who provide us with email marketing services. We consider Zoho to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within Zoho’s database for as long as we continue to use Zoho’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
3.5 Growth Capability Gap Analysis (GCGA) tool
Accessing and then completing the GCGA diagnostic tool will require visitors to fill in (a) a web form and then (b) 2 questionnaires. The personal data collected is the person’s name and email address. The web form data will be handled in the same way as the contact form data in 3.4 (above). The questionnaire data will be processed and held on a SiteGround UK-hosted database. This data will be anonymised – that is, held without personal details attached and used for further analysis and industry comparison purposes.
3.6 Partner or sponsored links
3.7 Social media policy & usage
Our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about social media privacy and usage policies on social media platform sites.
3.8 Downloads & media files
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti-virus software or similar applications. We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party anti-virus software or similar applications.
3.9 Embedded content
- HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.2 above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion, which is a limitation of the WordPress content management system that this website is built on. In the future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
- ABOUT THIS WEBSITE’S SERVER
This website is hosted by SiteGround Hosting Ltd (SiteGround) within a UK data centre located in the London area. The facilities are well protected by 24×7 human security, biometric access control, man traps, bullet proof lobbies and video surveillance. Details of SiteGround’s data centres can be found here: https://www.siteground.com/datacenters.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
- OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. These third parties are based in the USA or EU and are all EU-U.S Privacy Shield compliant. Here are links to the relevant privacy and GDPR policies of those organisations:
- Google: https://policies.google.com/privacy
- Zoho: https://www.zoho.eu/gdpr.html
- SiteGround: https://www.siteground.com/blog/siteground-is-gdpr-compliant
- DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
- DATA CONTROLLER
The data controller of this website is:
- Company: Commercial Impact Index Limited, a UK private limited company
- number: 10428462
- Registered office: Traviss & Co, 38 Newtown Road, Liphook, GU30 7DX
- Operating office: Hythe House, 55 Telegraph Lane, Four Mark, Hampshire, GU34 5AX
9. DATA PROTECTION OFFICER
The Data Protection Officer (DPO) of this website is:
- Name: Harry Cruickshank
- Title: Director, Commercial Impact Index Limited
- Email: firstname.lastname@example.org
- Telephone: 07770 741624