privacy notice

For website visitors and clients

BACKGROUND:


Steve O’Neill understands that your privacy is important to you and that you care about how your personal data is used. I respect and value the privacy of all of my clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.

1. Information About Me

Steve O’Neill

Sole trader (sondevelopment and steveoneillvoice)

Registered with the Information Commissioner’s Office.


2. What Does This Notice Cover?

This Privacy Information explains how I use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.


3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that I use is set out in Part 5, below.


4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which I will always work to uphold:

  • The right to be informed about my collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 11.

  • The right to access the personal data I hold about you. Part 10 will tell you how to do this.

  • The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 11 to find out more.

  • The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that I hold. Please contact me using the details in Part 11 to find out more.

  • The right to restrict (i.e. prevent) the processing of your personal data.

  • The right to object to me using your personal data for a particular purpose or purposes.

  • The right to withdraw consent. This means that, if I am relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

  • The right to data portability. This means that, if you have provided personal data to me directly, I am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.

  • Rights relating to automated decision-making and profiling. I do not use your personal data in this way

For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data I hold about you changes, please keep me informed as long as I have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. I would welcome the opportunity to resolve your concerns myself, however, so please contact me first, using the details in Part 11.


5. What Personal Data Do You Collect and How?

I may collect and hold some or all of the personal and non-personal data set out below, using the methods also set out below. I do not collect any ‘special category’ or ‘sensitive’ personal data OR personal data relating to children OR data relating to criminal convictions and/or offences.


Data Collected

  • Identity Information including Name, Title, Date of Birth, Gender

  • Contact information including address, e-mail address, telephone number.

  • Business information including business name, job title, profession.

  • Imagery including still photos and moving video imagery. Audio records.

How I collect the Data

  • Training records from attendance at my training activities.

  • Records of completion of online or virtual training activities.

  • Supplied to me by you or your organisation in regard to attendance or completion of one or more of my training activities.

  • Electronically (e-mail, cookie identifiers, IP addresses) as a result of your enquiry online or in-person regarding interest in the various services I provide.

  • Payment information including card details, bank account numbers.

  • BACS/Direct payment into my bank account. Paypal.

  • Use of proprietary meeting software such as (but not limited to) Zoom, Skype, Teams, Zencastr and similar.

  • Supplied directly to me by you using the above, or alternative asynchronous methods of image and audio transfer.


6. How Do You Use My Personal Data?


Under the Data Protection Legislation, I must always have a lawful basis for using personal data. The following section describes how I may use your personal data, and my lawful basis for doing so:


What I Do

  • Administering my business.

  • Supplying my products AND/OR services to you.

  • Managing payments for my products AND/OR services.

  • Personalising and tailoring my products AND/OR services for you.

  • Communicating with you.

  • Supplying you with information by email AND/OR post that you have opted-in to (you may opt-out at any time by contacting steve@sondevelopment.com)

What Data I Use

  • Name, title, gender, job title, profession, job experience

  • Name, Address, E-mail, Telephone number, messaging service details.

  • Bank Details, Card Details

My Lawful Basis - Legitimate Interest

  • ​Recording attendance at training for your or your organisation’s benefit

  • For the proper keeping of business records

  • To analyse and create statistical reports to measure the quality and performance of our services

  • Supplying electronic training content

  • Delivering training to you or people in your organisation

  • Contacting you to arrange supply or delivery of products or services

  • Contacting you to arrange payment

  • Supplying invoices

  • Transacting payment

  • Keeping records of payments and invoices for business records and tax purposes.

  • Creating training and learning content and/or activities that suit your needs

  • Bespoke content where it is helpful to personalise it to improve the service to you

  • To make contact where it is reasonable and necessary in the running of the business and delivery of the products and/or services.

  • Supplying information about content, services or activities which may be of interest or use to you.





With your permission and/or where permitted by law, I may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on my products AND/OR services. You will not be sent any unlawful marketing or spam. I will always work to fully protect your rights and comply with my obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.

I will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

I do not use automated systems for carrying out decision-making OR profiling.

I will only use your personal data for the purpose(s) for which it was originally collected unless I reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If I do use your personal data in this way and you wish me to explain how the new purpose is compatible with the original, please contact me using the details in Part 11.

If I need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, I will inform you and explain the legal basis which allows me to do so.

In some circumstances, where permitted or required by law, I may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.


7. How Long Will You Keep My Personal Data?

I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):


Type of Data

  • Identity Information including name, title, date of birth, gender.

  • Contact information including address, email address, telephone number.

  • Business information including business name, job title, profession, length of experience in the role.

  • Payment information including card details, bank account numbers.

How Long I Keep It

  • For the duration of any contract we have with you, any service we provide for you, in line with any legal obligation for data retention (such as that for HMRC) or, primarily, until erasure is requested by you.

8. How and Where Do You Store or Transfer My Personal Data?

I will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

AND/OR

I may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.


The security of your personal data is essential to me, and to protect your data, I take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where I am]legally required to do so;

  • where data is stored electronically all associated equipment will remain password and/or encryption protected at all times.


9. Do You Share My Personal Data?

I will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.


If I sell, transfer, or merge parts of my business or assets, your personal data may be transferred to a third party. Any new owner of my business may continue to use your personal data in the same way(s) that I have used it, as specified in this Privacy Policy.


In some limited circumstances, I may be legally required to share certain personal data, which might include yours, if I am involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.


If any of your personal data is shared with a third party, as described above, I will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, my obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, I will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.


10. How Can I Access My Personal Data?

If you want to know what personal data I have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.


All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.


There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.

I will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, I aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date I receive your request. You will be kept fully informed of my progress.


11. How Do I Contact You?

To contact me about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Steve O’Neill)

Email address: steve@sondevelopment.com

Postal Address: 72 Deverell Place, Widley, Hampshire, PO7 5ED.


12. Changes to this Privacy Notice

I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if I change my business in a way that affects personal data protection.

Any changes will be made available by email to steve@sondevelopment.com. This Privacy Notice was last updated on 18th June 2021.