Definitions

Business	Petrie Buchanan
GDPR	General Data Protection Regulation.
Register of Systems	means a register of all systems or contexts in which personal data is processed.

 

1. Data Protection Principles

The Business is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General Provisions

1. This policy applies to all personal data processed by the Business.
2. The Responsible Person shall take responsibility for the Business’ ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.

3. Lawful, Fair and Transparent Processing

1. To ensure its processing of data is lawful, fair and transparent, the Business shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the Business shall be dealt with in a timely manner.

4. Lawful Purposes

1. All data processed by the Business must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. The Business shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Business’ systems.

5. Data Minimisation

1. The Business shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
2. The personal data held by the business shall be limited to individuals name and contact details.

6. Accuracy

1. The Business shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / Removal

1. To ensure that personal data is kept for no longer than necessary, the Business shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

1. The Business shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Business shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this. This information is anonymised and cannot be attributed to you.

Communications

We may (now, or at some time in the future) seek to use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be relevant to you. You will not be sent this information without your consent, which you are free to withdraw at any time. Should you withdraw your consent to receive communications from us, your Personal Information will be deleted.

Cookies

Cookies are small text files which are stored temporarily on your hard drive when you visit a website. By accepting cookies and continuing to use this website with cookies enabled, you agree to our use of cookies.

Generally, we use cookies for two reasons:

Firstly, we gather anonymous statistics via Google Analytics. This helps us to find out how the site is accessed and used, which in turn allows us to develop and improve our site. The information collected does not identify any user personally.

Secondly, some of the features of this site may use cookies to enable functionality within certain sections. None of these cookies provide any personal information to us. You are, of course, free to disable cookies on your browser, but please be advised that doing so may cause some sections of the site to function incorrectly or not at all.

For further information on cookies and our use of them, please refer to our Cookie Policy.

Security

The security of your Personal Information 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 Information, we cannot guarantee its absolute security.

External links

Within this site there may be links to other sites which are not controlled by this Privacy Policy. Should you access any of these sites, do please note that they have their own privacy policies which you should always inspect.

We reserve the right to modify or update this Privacy Policy at any time, without notice.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

Petrie Buchanan (“us”, “we”, or “our”) uses cookies on this website. By using this website, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on this website, your choices regarding cookies and further information about cookies.

This Website

This website has been built and integrated into the Joomla! Content Management System (CMS). Extra functions (galleries, calendars etc) often come from Joomla! ‘Extensions’ created by third-party developers. The CMS and the Extensions use cookies to enable certain functions of the site. These cookies do NOT collect and store personal information from site visitors on our behalf. Any information collected (as with Google Analytics) is anonymised.

What are cookies

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows this website or a third party to recognize you and make your next visit easier and this website more useful to you.

Cookies can be “persistent” or “session” cookies.

How Petrie Buchanan uses cookies

When you use and access this website, we may place a number of cookie files in your web browser.

We use cookies for a number of purposes: to enable certain functions of this website, to provide analytics and to store your preferences. We use both session and persistent cookies on this website and we use different types of cookies to run this website:

Essential cookies – We may also use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third party cookies

In addition to our own cookies, we may also use various third-party cookies to report usage statistics of this website, to enable third-party software, such as YouTube videos, and so on.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser and/or make use of the cookie consent banner at the foot of this site.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can you find more information about cookies

You can learn more about cookies and the following third-party websites:

All About Cookies: http://www.allaboutcookies.org/

Network Advertising Initiative: http://www.networkadvertising.org/