Compliance

Folding Space privacy practices are in compliance with the Freedom of Information Act 2000, the Privacy and Electronic Communications Regulations 2003, the Data Protection Act 2018 and the UK GDPR.

To ensure that any personal information is handled properly, we abide by the seven key principles set out by the Data Protection Act 2018 and the UK GDPR as cited by the ICO (Information Commissioners Office) https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-protection-principles/a-guide-to-the-data-protection-principles/

1. Lawfulness, fairness and transparency
2. Purpose limitation
3. Data minimisation
4. Accuracy
5. Storage limitation
6. Integrity and confidentiality (security)
7. Accountability

As per the ICO guidance, Folding Space acknowledges that - these principles should lie at the heart of your approach to processing personal data – and has embedded such within its approach to data privacy and through its ISO 27001 ISMS policies and certification.

Specifically, Article 5(1) of the Data Protection Act 2018 requires that personal data shall be:  

 “(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);

(b) 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 (‘purpose limitation’);

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

(d) 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 (‘accuracy’);

(e) 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 (‘storage limitation’);

(f) 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 (‘integrity and confidentiality’).”

Article 5(2) adds that:

“The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).”

Again, Folding Space acknowledges these principles which are embedded such within its approach to data privacy and through its ISO 27001 ISMS policies and certification.

Personal data

Under the Data Protection Act 2018 (UK GDPR), personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of that natural person”.

How we use your information

This privacy notice tells you how we, Folding Space, will collect and use your personal data for the delivery of our software solutions and performance of our services to you.

Why does Folding Space need to collect and store personal data?

In order for us to provide you with our services we may need to collect personal data for correspondence purpose and/or detailed product or service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Folding Space would contact you for additional consent. 

Will Folding Space share my personal data with anyone else?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. We may pass your personal data on to third party service providers contracted to Folding Space in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with Folding Space’s procedures. If we wish to pass your sensitive personal data on to a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Folding Space use the personal data it collects about me?

Folding Space will process (collect, store and use) the information you provide in a manner compatible with the Data Protection Act 2018 (UK GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Folding Space is required to retain information in accordance with the law, such as information needed for tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Folding Space contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that Folding Space holds about me?

Folding Space, at your request, can confirm what information we hold about you and how it is processed. If Folding Space does hold personal data about you, you can request the following information:

• Contact details of our Data Protection Officer, where applicable.
• The purpose of the processing as well as the legal basis for processing
• If the processing is based on the legitimate interest of Folding Space or a third party, information about those interests.
• The categories of personal data collected, stored and processed
• Recipient(s) or categories of recipients that the data is/will be disclosed to
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored
• Details of your rights to correct, erase, restrict or object to such processing
• Information about your right to withdraw consent at any time
• How to lodge a complaint with the supervisory authority
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
• The source of personal data if it was not collected directly from you
• Any details and information of automated decision making, such as profiling and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing

How do we protect your data?

We are ISO 27001 certified which means that our Information Security Management System (ISMS) fully satisfies the exacting requirements set by ISO 27001:2013 as independently verified by an ISO accredited auditor.

• ISO 27001:2013 is the current standard and specification for an ISMS that is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organisation's information risk management processes.
• ISO 27001:2013 certification demonstrates that we have identified the risks, assessed the implications and put in place systemised controls to ensure for the highest standards of reliability and security in our systems and information handling, processing and storage.

We follow appropriate security procedures in the collection, storage and use of your Information so as to prevent unauthorised access by third parties. We process data at our offices at our Birmingham address, with access restrictions in place and at the sites of our data processors within the UK.

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

We have put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.

However, unfortunately, the transmission of Information via the Internet is not completely secure. We cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the GDPR, The Privacy and Electronic Communications Regulations or the Data Protection Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.

Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to Information collected by us through our website or services and does not apply to these third-party websites and third-party service providers.

Contact information

If you have any questions regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, please write to us for the attention of - The Company Secretary, Folding Space, Regent House, 70 Caroline Street, Birmingham B3 1UG. Alternatively, you may email via studio@foldingspace.co.uk.