The General Data Protection Regulation (GDPR), the new Data Protection Regulation, comes into force on May 25th 2018, with the aim of unifying and strengthening data protection for all EU citizens.
When we refer to “Recovery4Life Ltd”, we mean the Recovery4Life Ltd entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Table of Contents:
- Information We Collect and Receive
- How We Use Information
- Lawful Basis
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- Data Protection Officer
- Identifying the Data Controller and Processor
- Your Rights
- Contacting Recovery4Life Ltd
- Contacting the ICO
A separate agreement governs delivery, access and use of Recovery4Life Ltd’s Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through services accounts (collectively, “Customer Data”). The organisation (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their services (“Account”) and any associated Customer Data.
Information We Collect and Receive
Recovery4Life Ltd may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
Customer Data. Customers or individuals granted access to an account by a Customer (“Authorised Users”) routinely submit Customer Data to Recovery4Life Ltd when using the Services. This may include sensitive and confidential personal information.
Other Information. Recovery4Life Ltd also collects, generates and/or receives Other Information such as:
- Account Information. To create or update an Account, you or your Customer (e.g., your employer) supply Recovery4Life Ltd with an email address, phone number, password, domain and/or similar account details, delivery and contact information, Company registration details and details around the service provision required. For details on Account creation, click here In addition, Customers that purchase Services provide Recovery4Life Ltd (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
- Website Information. Information about your use of our website including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data. Information provided voluntarily by you. For example, when you register information or make a purchase
You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
- Additional Information Provided to Recovery4Life Ltd. We receive Other Information when submitted to our website or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Recovery4Life Ltd.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Account setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Recovery4Life Ltd in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement, and as required by applicable law. Recovery4Life Ltd is a processor of Customer Data and Customer is the controller.
Recovery4Life Ltd uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Recovery4Life Ltd uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Recovery4Life Ltd. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Recovery4Life Ltd may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
Recovery4Life Ltd control and process data based on the following:
Consent – Consent is required and requested for processing sensitive data and when sending out information for marketing purposes.
Contract – Other information is processed because it is necessary for fulfilling a contract or because specific steps need to be taken before entering into a contract.
Recovery4Life Ltd will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement, and as required by applicable law.
Records are retained as specified by legal requirements, guidelines from the appropriate professional authorities or as defined in the service level agreement or contract. In absence of such guidance, the default storage of paper records is 6 years from creation.
Electronic records including Drug and Alcohol screening reports are stored indefinitely provided that future hardware and software systems are capable of accessing the data. The data may be printed to hardcopy if required.
Where no specific retention period is shown, the records are held for 6 years as live, after which they are archived on the server.
Paper records are disposed of by shredding to ensure that confidentiality is maintained.
How We Share and Disclose Information
This section describes how Recovery4Life Ltd may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Recovery4Life Ltd does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Recovery4Life Ltd will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement, and in compliance with applicable law and legal process.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These suppliers and other third parties are not authorised by us to use your Personal Data in any other way than in the delivery of Recovery4Life Ltd. products and services.
- During a Change to Recovery4Life Ltd’s Business. If Recovery4Life Ltd engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Recovery4Life Ltd’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Recovery4Life Ltd or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Recovery4Life Ltd may share Other Information with third parties when we have consent to do so.
Recovery4Life Ltd takes security of data very seriously. Recovery4Life Ltd works hard to protect Other Information you provide from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Recovery4Life Ltd cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others. The Company does not accept responsibility for any loss arising from unauthorised access to, or interference with, any internet communications by any third-party, or from the transmission of any viruses.
To the extent prohibited by applicable law, Recovery4Life Ltd does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.
Data Protection Officer
Our size and services provided mean that we do not require a designated onsite Data Protection Officer but if you have any concerns, please email firstname.lastname@example.org
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Recovery4Life Ltd is the processor of Customer Data and the controller of Other Information.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, withdraw consent or correct this Information.
- To request a copy of any personal information held about you, email precise details of the request email@example.com or write to Recovery4Life, Arch 6, Hymers Court, Brandling Street, Gateshead, NE8 2BA. There will be a charge of £10 for this service.
- To update, delete, withdraw consent or correct your personal information, email precise details of the request to firstname.lastname@example.org
To the extent that Recovery4Life Ltd’s processing of your Personal Data is subject to the General Data Protection Regulation, Recovery4Life Ltd relies on its legitimate interests, described above, to process your data. Recovery4Life Ltd may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Recovery4Life Ltd’s use of your Personal Data for this purpose at any time. To do this email: email@example.com with the request.
Contacting Recovery4Life Ltd
Recovery4Life, Arch 6, Hymers Court, Brandling Street, Gateshead, NE8 2BA
T: 03333 448 288 E: firstname.lastname@example.org
Contacting the ICO
If you believe there is a problem with the way Recovery4Life is handling your data, individuals have the right to complain to the ICO.