Last Updated: May 14th, 2019
Midshore Consulting Limited and Midshore Consulting USA LLC (collectively “Midshore Consulting”, “us”, “we”, or “our”) operates the www.midshoreconsulting.com website (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Midshore Consulting is a business providing the following services:
- Consultancy Services
- Training Services
- Website, Design & SEO Services
In providing these services, Midshore Consulting needs to gather and use certain information about individuals in the provision of those services – it is a Data Controller. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact (“data subjects”).
This policy describes how this personal data must be collected, handled and stored to meet the business’ data protection standards – and to comply with relevant law and regulation.
Why this policy exists
This data protection policy ensures that Midshore Consulting:
- Complies with data protection law and follows good practice
- Protects the rights of employees, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Relevant law and regulation
The following laws and regulations describe how organisations – including Midshore Consulting – must collect, handle and store personal information:
- U.S. Privacy Act of 1974 (the “U.S. Law”)
- The Data Protection (Bailiwick of Guernsey) Law, 2017 (the “Guernsey Law”)
- Ordinances and regulation promulgated under the Guernsey Law
- The General Data Protection Regulation (the “GDPR”) of the European Union – with respect to its extraterritorial nature
- Any other international or foreign legislation that may, by reason of its extraterritorial nature, have impact on the processing of personal data in the Bailiwick of Guernsey
These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the relevant laws and regulations, personal information must be collected and used fairly, stored safely, kept up to date and not disclosed unlawfully.
The requirements of data protection laws and regulations are underpinned by seven principles, the first six of which state that personal data must:
- Be processed lawfully, fairly and in a transparent manner
- Be obtained only for specific, explicit and legitimate purposes and must not be processed in a manner incompatible with the purpose for which it was collected
- Be adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed
- Be accurate and, where applicable, kept up to date with reasonable steps being taken to ensure that personal data that is inaccurate is erased or corrected without delay
- Not be kept in a form that permits identification of the data subject any longer than is necessary for the purpose for which it is processed
- Be processed in a manner that ensures its security appropriately, including protecting it against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
The seventh principle applies to data controllers, including Midshore Consulting, and states that such data controllers are responsible for, and must be able to demonstrate, compliance with the other six principles.
Data controllers also have an obligation to facilitate exercise of the rights of data subjects (the “Rights”).
What are Cookies?
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies – We use Session Cookies to operate our Service
- Preference Cookies – We use Preference Cookies to remember your preferences and various settings
- Security Cookies – We use Security Cookies for security purposes.
For more general information on cookies see the Wikipedia article on HTTP Cookies…
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.
The Cookies We Set
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, Twitter, LinkedIn, YouTube, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Finally, our websites use Hotjar Analytics, this is done by a tracking code and allows our team to look at the way users browse our website (anonymously). This data is stored without any recognisable data and allows our team to make informative changes to improve user experience.
If you wish to not be tracked by Hotjar, please see their guide here.
Information Collection And Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information may include, but is not limited to:
- Email address
- First Name and Last Name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Dispatch address and Name
- Cookies and Usage of Data
Usage of Data
We may also collect information on how the Service is accessed and used (“Usage of Data”). This Usage of Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Personal data is of no value to Midshore Consulting unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft.
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside the Bailiwick of Guernsey, the European Economic Area or an equivalent jurisdiction, unless previously approved by the board due to there being some mechanism in place.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Midshore Consulting Limited uses the collected data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside of Guernsey and choose to provide information to us, please note that we transfer the data, including Personal Data, to Guernsey and process it there.
Disclosure of Data
Midshore Consulting Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Midshore Consulting Limited
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Disclosing data for other reasons
There are other circumstances where personal data may be disclosed, without consent of the data subject. This includes situations where the data must be disclosed by reason of local legislation or international agreement.
Under these circumstances, Midshore Consulting will disclose the requested data. However, the data controller will seek to ensure the request is legitimate, with approval from the board and legal advisers as appropriate.
General data protection policies relating to staff
- The only people able to access data covered by this policy should be those who need it in respect of the function(s) they perform
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line manager.
- Midshore Consulting will provide training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure, by taking sensible precautions and following this policy and related procedures.
- Strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the business or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of as detailed in the Data Retention Policy.
- Employees should request help from their line manager or the person responsible for data protection if they are unsure about any aspect of data protection.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Details of our websites security certificate can be seen by clicking on the padlock – how this is done is dependant on your browser, so please consult the help section.
Data Protection Risks
This policy helps to protect Midshore Consulting from data security risks, including:
- Breaches of confidentiality, for example information being given out inappropriately
- Failing to offer choice, for example all individuals should be free to choose how the business uses data relating to them
Reputational damage, for example the business could suffer if hackers successfully gained access to sensitive data
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or the person responsible for data protection.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. This also applies to data that is usually stored electronically but has been printed out.
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (CD, DVD, USB flash drive or external hard drive), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the business’ standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data should be protected by approved security software and a firewall.
The law requires Midshore Consulting to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary instances of personal data.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Midshore Consulting will make it easy for data subjects to update the information held in respect of them.
- Data should be updated as inaccuracies are discovered and as clients advise that it requires updating.
Subject Access Requests
All individuals who are the subject of personal data held by Midshore Consulting are entitled to:
- Ask what information the company holds about them and why
- Ask how to gain access to it
- Be informed how to keep it up to date
- Be informed how the company is meeting its data protection obligations
If an individual contacts the business requesting this information, this is called a subject access request. Subject access requests can be received from the data subject by mail or email.
An individual making a subject access request can request a single copy of their data free of charge. The business will aim to respond to this within 14 days. If the individual requests further copies of their data, then administrative costs can be charged at standard rates.
The business will always seek to verify the identity of the individual making a subject access request prior to providing them with any information.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We use service providers such as PayPal to make it easier for our customers to pay for our training courses / documents / events online. A copy of PayPal’s Terms & Conditions can be found on their website.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Privacy for Children
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child/Children has/have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
This policy applies to:
- Midshore Consulting
- All staff of Midshore Consulting
- All contractors, suppliers, outsource providers and other people working on behalf of Midshore Consulting
It applies to all data that the business holds relating to identifiable individuals, whether or not that data falls under the provisions of relevant data protection legislation, including:
- Names of individuals
- Postal and physical addresses
- Email addresses
- Telephone numbers (including mobile telephone numbers)