Privacy Notice

UK GDPR

Welcome to Sycamore Disability and Business’s privacy notice. This privacy notice is intended for clients and potential clients. If you are a supplier, please see our Supplier Privacy Notice.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to provide information on how we collect and process your personal data (including when you visit our website), your privacy rights and how data protection law protects you.

This privacy notice is provided in a layered format so you can click through to the areas set out below.

1. Who we are and important information

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide through our website (i.e. filling in our contact form), signing up for administrative services or contacting us directly through Whatsapp, email or phone call.

Our website and services are not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Sycamore Disability and Business is the controller and responsible for your personal data (collectively referred to as “Sycamore Disability and Business”, “we”, “us”, or “our” in this privacy notice. Our contact details are:

Address: Sycamore Disability and Business Limited, Desklodge House, 2 Redcliffe Way, Redcliffe, Bristol BS1 6NL

Company number: 16269722

Email: alice@sycamorebusiness.co.uk

Telephone: 07472458031

For all data matters contact Alice Hastie using the contact details above.

Third-party links outside of our control

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner’s Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, pronouns, date of birth and gender identity
Contact Data includes postal address, email address and telephone number
Usage Data includes information on your use of our products and services
Special Category – Health Data includes information about your physical and mental health as well as your neurotype.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to work as your Access to Work support worker). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

3. How we collect your personal data

We use different methods to collect data from and about you including:

Directly. You may give us your Identity, Contact, Usage and Special Category data by filling in forms, corresponding with us by post, phone, email or otherwise, or purchasing our services. This includes personal data you provide when you:
- Make any enquiry via our website contact form, Whatsapp, email, social media or other method
- Fill in and sign a contract for services
- Attend working sessions face-to-face or over video call
Indirectly from publicly available sources. We may collect Identity and Contact data from publicly available sources such as organisational websites, Companies house, and registers for legislative purposes.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract. This means processing data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legitimate Interest. This means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where are interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details in Section 1.
Comply with a legal or statutory obligation. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent. This means you have explicitly consented to our processing of your personal data for a specific purpose. You have the right to withdraw consent at any time by contacting us using the details in Section 1.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details in Section 1 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To respond to enquiries from you	(a) Identity (b) Contact (c) Special Category – Health	(a) Necessary for our legitimate interests (to gain new clients and to provide good customer service) (b) Consent
To provide you with a quote	(a) Identity (b) Contact	(a) Performance of a contract with you
To onboard you as a new client including: (a) Signing a Contract (b) Adding you as a contact in our accounting software (FreeAgent) (c) Adding you as a contact in Google (d) Creating a shared Google Drive folder to collaborate on work (e) Gaining access to your software accounts you want us to work on (i.e. MailChimp, Meta Business Suite) (f) Issuing you with an invoice for our services	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
To manage our relationship with you including: (a) Responding to communications via phone call, email, Whatsapp, social media and others (b) Arranging face-to-face sessions or calls (c) Make adjustments for your disability, physical or mental health problem or neurodivergence.	(a) Identity (b) Contact (c) Special Category – Health	(a) Performance of a contract with you (b) Consent
To invoice you for goods and services we have provided	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
To send you relevant promotions and marketing based on your previous use of our services	(a) Identity (b) Contact (c) Usage	Necessary for our legitimate interests (to sell further services to existing and past clients)
To send relevant direct marketing to your business/corporate organisation	(a) Identity (b) Contact	Necessary for our legitimate interests (to find new clients and grow our business)

Opting out

You can ask us to stop sending you marketing messages at any time by contacting us directly using the contact details in Section 1.

Where you opt out of receiving these marketing messages, this will not apply to messages relating to a product or service you have purchased. For example you will still receive messages from us relating to a service we are contractually providing to you.

Cookies

When using our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details in Section 1.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above:

External third-party service providers:
- Providers acting as processors based in the UK who provide administrative, marketing or technical services
- Professional advisors acting as joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities acting as joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third-party processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the UK.

7. Data security

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

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of ham from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by using the contact details in Section 1.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

The right to request a copy of the personal data we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics.

If you wish to exercise any of the rights set out above, please contact us using the contact details in Section 1.

No fee required - with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Changes to this notice and your duty to inform us of changes

This version was last updated on 03 February 2024 and historic versions can be obtained by contacting us using the details in Section 1.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us using the details provided in Section 1.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office as follows:

Address: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline: 0303 123 1113

Website: https://ico.org.uk/make-a-complaint/