Privacy Policy - Working Feedback

Privacy Policy

Updated March 2021


1. Background

  1. This privacy policy sets out how we use your personal data and what your rights are in respect of it.
  2. We may change this privacy policy from time to time and without notice. If we make significant changes in the way we treat your personal information, or to the privacy policy, we will make that clear on our website, or by some other means such as email, so that you are able to review the changes before you continue to use our website.
  3. This page was last updated on 4th March 2021.

2. Our Details

  1. Cade Directories Limited is a limited company registered in England with the company registration number 05868356
  2. and our registered address at 1a The Old Greenhouse Shedfield Equestrian Centre, Botley Road, Shedfield, Hampshire, England, SO32 2HN.
  3. Our Data Protection Officer is Mr Philip Molden email [email protected]

3. If you wish to contact us in relation to this policy, or data protection generally, please contact us by:

  1. telephone on 0800 043 2100;
  2. email on [email protected]
  3. post using the registered address above.

4. Our relationship to you and your personal data

  1. Our legal status in relation to you and your personal data differs, depending on where you are in the review process, which we explain in this section. You should contact the “controller” of your data, as indicated below.

5. Emails and/or SMS inviting you to submit a review

  1. Here, we act as data processor, solely on behalf and on the instruction of our client.
  2. Where we email you or send you an SMS to ask you to submit a review in respect of our clients service or product, that client has given us your details, and asked us to send you such communication.
  3. We will not use your name, email address or mobile telephone number for any other purpose, unless we already hold it in respect of a review . Even where we already hold your name, email address or mobile telephone number, we will only invite you to submit a review where our client has provided the same details.

6. When you visit our website, and your review itself (and any other data you submit with it)

  1. Here, we act as data controller.
  2. When you visit our website, we will automatically collect certain personal data using cookies and your IP address.
  3. We may also collect personal data contained in any forms you submit to our website, including the details of any review you submit.
  4. The purposes for which we use your personal data are set out in the table below.
  5. Please note that our client will also be a data controller of review data, and you may need to contact both us to exercise rights in respect of your personal data.

7. Who you should contact in relation to your personal data and your rights

  1. Where Working Feedback is the “controller”, as set out in paragraph 3 above, you should direct any queries you have in relation to your personal data to Working Feedback.
  2. Where Working Feedback is the “processor”, as set out in paragraph 3 above, you should direct any queries you have in relation to your personal data to the client in question.

8. The processing

  1. This privacy policy applies to customers of our clients that use our services, and visitors to our website.
  2. Where indicated, we carry out that activity as the data processor of our client, and any queries you have in relation to such activity should be directed to them.

9. Customer Feedback Service (We act as a Data Processor)

  1. Type of data Your contact details including name, email address and/or mobile telephone number.

    The Purpose To invite you to submit a review upon the instruction of our client

    Legal basis for the processing As a data processor, we are not responsible for establishing a legal basis. Our client, as data controller, must have the legal basis. Legal requirement for our client, such as NHS Contracts and/or CQC requirements and/or FCA Requirements

    How Long we keep it We keep data for any published reviews for as long as the review is being displayed publicly for verification purposes. We also have a legal requirement to share data with the NHS but only on reviews with more than 100 characters and the client is a registered entity with them and have a ODS Code.
  2. Type of data Feedback Data, including name, rating and text. Where you have asked us to keep your review anonymous, we will not publish any identifying information about you, this applies across all means of publishing.

    The Purpose To publish your review on our websites. To supply our client with a variety of digital feeds of their reviews for publication Our client to be able to review in the dashboard.

    Legal basis for the processing Part of our terms and conditions and delivery of our service

    How Long we keep it We keep data for any published reviews for as long as the review is being displayed publicly for verification purposes. We also have a legal requirement to share data with the NHS but only on reviews with more than 100 characters and the client is a registered entity with them and have a ODS Code.
  3. Type of data Feedback Request data, Name, Email address or Mobile Phone Number

    The Purpose To collect reviews from our clients customers.

    Legal basis for the processing Part of our terms and conditions and delivery of our service

    How Long we keep it If no feedback is left, we will delete all data after 28 days. Where a client has specified that they do not wish for a person to be contacted in a extended time period we will keep the data on file for that length of time to ensure that the person who has been asked does not get asked again.

10. Customer Feedback Service (We act as a Data Handler)

  1. Type of data Your Name, Email Address, Phone number

    The Purpose To send you marketing communication emails which we believe will be of interest to you. To arrange a demonstration of our service To arrange onboarding of our service

    Legal basis for the processing We will always ask for your opt in consent.

    How Long we keep it We will keep the data as long as you are a client or prospect and you can always opt out if you no longer wish to receive marketing communications.

11. Where multiple retention periods apply to the same personal data, the retention period will be the longest one (although we will stop using such personal data for a purpose when the retention period for that purpose expires).

12. Where our legal basis for processing is legitimate interests, you may have the right to object to our processing (see the section titled “Objecting to legitimate interests processing” below).

13. Where we obtain your personal data from

  1. We obtain your personal data in the following ways:
    • (a) from our clients (although as their data processor);
    • (b) directly from you, for instance where you submit to our website, communicate with us, or otherwise voluntarily providing personal data to us; and
    • (c) from your accounts on other website, where you give us permission to do so. For instance, if you use Facebook or Twitter to log into our website, we may obtain some information from those websites;
    • (d) automatically when you use our website. For instance:
  2. like most websites, we use cookies (which are smaller text files sent between your web browser and our services) to provide or improve certain functionality and to track which of our pages you visit (see our the “Cookies” section below for more information); and
  3. our web server automatically collects certain information about your use of our website, for instance some key settings on your device, what type of device you are using, the operating system on your device, the website from which you came and your IP address.

14. Persons with whom we may share your data:

  1. All review data is shared with our client in respect of which you submitted a review (unless you specifically requested anonymity).
  2. In general, internal access to your personal data will be restricted to those who have a need to access it in order to carry out their duties (for example, our moderation).
  3. However, we will also share your personal data with the following external third parties in some circumstances:
    • (a) regulators such as the ICO, and government authorities such as NHS, FCA, CQC or the Police, if we are required to do so by law or if the regulator or authority requests it and we regard that request as reasonable or are required to comply by law.
    • (b) our insurers, legal advisers or other third parties who need access to it in the context of managing, investigating, or defending claims or complaints;
  4. Where we have been able to fully anonymise personal data, we may share that anonymised data with third parties, for instance our clients to share market trends or consumer sentiment, or in PR material that we publish.

15. Withdrawing consent

  1. Where we process your personal data on the basis of consent for marketing purposes, you can withdraw your consent in one of the following ways:
  2. by following the unsubscribe link which we include in all of the electronic marketing we send; or
  3. by contacting our team using the email address [email protected]

16. Objecting to our legitimate interests processing

  1. Where we process your personal data for direct marketing purposes, you always have the right to object to that processing.
  2. You have the right to object to other processing on the basis of our legitimate interests, but we might not have to cease processing where you do so if either:
    • (a) we are able to demonstrate compelling legitimate grounds for the processing which override your interests; or
    • (b) where that legitimate interest is the establishment, exercise or defence of legal claims.
  3. To object to legitimate interests processing, please contact us.

17. Your rights

  1. The law gives you certain rights in respect of the personal data that we hold, which you should be aware of:
  2. You have the right to obtain your personal data from us except in limited circumstances. Where we provide it, the first copy will be free of charge, but we reserve the right to charge a small fee for additional requests.
  3. You have the right to require us to rectify any inaccurate personal data we hold concerning you.
  4. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data completed, by means of providing a supplementary statement or otherwise.
  5. You have the right to require us to erase your personal data
  6. Where we process personal data either on the basis of consent or contractual necessity, you provided the personal data to us, and we process that personal data by automated means, you have the right to require us to give you your data in a commonly used electronic format;

18. You have the right to require us to restrict the processing of your personal data on certain grounds, including where:

  • (a) you contest the accuracy of the personal data and want us to restrict processing of your personal data while we verify its accuracy;
  • (b) the processing is unlawful, but you request a restriction of the processing rather than erasure;
  • (c) we (as controller) no longer need the data for the purposes of the processing, but you have told us you require us to retain that personal data for you to establish, exercise or defend legal claims; or
  • (d) you have objected to us processing your personal data on grounds of legitimate interests and want us to restrict processing of your personal data while we consider your objection.
  • (e) If you would like to exercise any of these rights, please contact us using email address [email protected]

19. Cookies

  1. The Website uses cookies. Cookies are digital information which is stored on your computer. The cookie does not identify the individual user but the user's computer, and it is used for different purposes.

20. Third party cookies

  1. We may provide cookie and a de-identified data to trusted 3rd parties, this data is used for matching to other data about you to improve the relevance of online advertising and personalisation. Your actual email address is at no time shared with our 3rd party partners. Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third-party Cookies may be set:
  2. Google Analytics Cookies, set when you log in to our Website with Google
  3. Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google

21. Deletion of cookies

  1. You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu In most browsers.

22. Age Requirements - 18 or older

  1. We require our users to be 18 or older and anyone using the site must adhere to this rule. We never knowingly allow children under 18 to post personal information on our site. If you know about someone using the website under the age of 18 please contact us via [email protected].

23. Right to complain to the information commissioner

  1. If you have any concerns or comments about how we use your data, we would like to hear from you. Alternatively, you may contact the information commissioner’s office (ICO) for guidance and advice or to lodge a complaint. The ICO can be contacted at www.ico.org.uk by post Wycliffe House, Water Lane, Wimslow, Cheshire, SK9 5AF. Telephone 0303 123 1113 (local rate) or 01625 545 745 (national rate).
  2. Click Here to see our Registration.