Privacy Policy

Who processes your information?

Tom Hogan collects personal data in order to carry out his business. As a sole trader he holds data on clients, colleagues and others, such as customers and contractors. He takes the issue of privacy very seriously and is committed to protecting and respecting your privacy in compliance with data protection law.

Tom Hogan is the data controller of the personal information you provide to him and which he stores. He is responsible for the accuracy and safe-keeping of data. He determines the purposes for which, and the manner in which, any personal data relating to colleagues, contractors and costumers is to be processed.

All data is stored in accordance with GDPR regulations. In some cases, your data will be outsourced to a third party processor. Where he outsources data to a third party processor, the same data protection standards that he upholds are imposed on the processor

Some Important Definitions

‘He’ means Tom Hogan
‘ICO’ is the Information Commissioner’s Office, the body responsible for enforcing data protection legislation within the UK and the regulatory authority for the purposes of the GDPR
‘Personal Data’ is defined in section 3
‘Processing’ means all aspects of handling personal data, for example collecting, recording, keeping, storing, sharing, archiving, deleting and destroying it.
‘Data Controller’ means anyone (a person, people, public authority, agency or any other body) which, on its own or with others, decides the purposes and methods of processing personal data. We are a data controller insofar as we process personal data in the ways described in this policy.
‘Data processor’ means anyone who processes personal data under the data controller’s instructions, for example a service provider. I act as a data processor in certain circumstances.
‘Subject Access Request’ is a request for personal data that an organisation may hold about an individual. This request can be extended to include the deletion, rectification and restriction of processing.

The information he collects

The categories of client/family information that he collects, hold and shares include:

Personal information (including some parental information) such as name, membership number and address
Photographs and Videos
Characteristics (such as ethnicity, language, nationality, country of birth)
Achievement information (such as awards received)
Medical information
Special Educational Needs and Disability
Financial and Gift Aid Information
Why we collect and use this information

Tom Hogan is required by law to hold certain information in order to fulfil its obligations for safeguarding members in its care. Additionally, some information is retained for planning purposes, to aid programme planning and delivery, and for historical and statistical purposes. Finally, some information is used for publicity of Tom Hogan projects, and marketing events to clients colleagues and costumers.

Conditions for collecting personal data

Keeping to the law
He must keep to the law when processing personal data. To achieve this, he has to meet at least one of the following conditions:
you have to give (or have given) your permission for us to use your information for one or more specific purposes
we need to process the information to meet the terms of any contract you have entered into

processing the information is necessary to keep to our legal obligations as data controller
processing the information is necessary to protect your vital interests
processing the information is necessary for tasks in the public interest or for us as the data controller to carry out our responsibilities
processing the information is necessary for our legitimate interests (see below)

Also, information must be:

processed fairly and lawfully
collected for specified, clear and legitimate purposes
adequate, relevant and limited to what is necessary accurate and, where necessary, kept up to date
kept for no longer than is necessary
processed securely

Information that he shares

He may have to share your personal, as long as this is necessary and directly related to your role within Tom Hogan projects. He does not share personal data with companies, organisations, unless one of the following applies;

He has clear permission from you to do so.
If he has to supply information to others (for example payroll providers) for processing on our behalf. He will do this if he is asked and to make sure that they are keeping to the GDPR and have appropriate confidentiality and security measures in place.
For safeguarding young people or for other legal reasons.
Data is also stored in Google Drive and Dropbox for the purposes of administering his projects.
He shares data with his website host and Facebook for the purposes of publicity and celebration.
We share data with our bank and HMRC for the processing of payments/refunds

Keeping personal data secure

Everyone who handles personal data (including staff, members, volunteers, payroll and pension providers) must make sure it is held securely to protect against unlawful or unauthorised processing and accidental loss or damage. Tom Hogan takes appropriate steps to make sure we keep all personal data secure, and we make all contracted staff aware of these steps, including keeping to our internal information and computing technology (ICT) policy. In most cases, personal data must be stored in appropriate systems and encrypted when taken off-site. The following is general guidance for everyone working with Tom Hogan, including staff, contractors and volunteers.

Your rights

Clients have the following rights in relation to the processing of their personal data. You have the right to:

be informed about how Tom Hogan uses your personal data.
request access to the personal data that Tom Hogan holds.
request that your personal data is amended if it is inaccurate or incomplete.
request that your personal data is erased where there is no compelling reason for its continued processing.
request that the processing of your data is restricted.
object to your personal data being processed.
Where the processing of your data is based on your consent, you have the right to withdraw this consent at any time.
If you have a concern about the way Tom Hogan is collecting or using your personal data, we request that you raise your concern with us in the first instance.
Alternatively you can contact the Information Commissioner’s Office (ICO) on 0303 123 1113, Monday-Friday 9am-5pm or at https://ico.org.uk/concerns/

Tom Hogan