Privacy Notice

Fresh Management Solutions understands that we have a responsibility to protect and respect personal data and privacy. This Privacy Notice explains what personal data we collect, how it’s used, stored and the reasons it may need to be disclosed to others.

Fresh Management Solutions Ltd is committed to the principles of data protection. This commitment is good management practice and makes sound business sense: the benefits for the company include legal compliance and positive relations with external stakeholders such as clients, learners and suppliers.

The EU has introduced the General Data Protection Regulation (or “GDPR”). The GDPR has brought a huge change to the way personal data is protected throughout Europe (from 25th May 2018).

This Privacy Notice takes effect from the 1 December 2018. It is subject to change, so please check our website https://www.freshmanagementsolutions.co.uk/ on a regular basis for any further changes.

WHO ARE WE

Fresh Management Solutions Ltd is a learning provider and consultancy. We help individuals and people in businesses, charities, social enterprises and support agencies to know more, achieve together and work smarter. We provide leadership and management development programmes under our Learn, Love, Look ahead brand.

OUR ROLE

Fresh Management Solutions is both a data controller and data processor depending on circumstances. We are a data controller when we collect and keep a record of your data in order to provide our services. We are a data processor when we process the data.

In what capacity will we hold personal information about you?

During the course of providing services, we compile and hold certain personal information about living and deceased individuals for the purposes of delivering training courses and programmes, coaching and mentoring services, consultancy and business advice services, seminar and event, and marketing.

This may include personal information about current and past employees, clients, the family and/or partners of clients, suppliers and others with whom we communicate, and other third parties.

WHAT PERSONAL DATA WE COLLECT

Fresh Management Solutions may collect, store, and use the following types of personal information:

• Contact details, such as name, title, addresses (or approximate location i.e. postcode), telephone numbers, fax number, email addresses
• Date of birth, age
• Gender
• National Insurance Number
• Third party contact details, these will be provided by you and used and stored by Fresh Management Solutions on the understanding you have informed the individual to whom the data belongs
• Signature
• Appointments
• Job title, employer/organisation, registered business/charity number
• Photographs
• Social media handles.
• IP address
• Bank details
• Customer data (which in addition to the above may include details of services purchased, courses attended).

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect personal information from and about you.

Directly from you: Typically, the personal information that we collect about you will be the personal information that is input onto the website or provided in face-to-face meetings either in person or online. In some instances, however, it could be provided in other electronic formats, on application forms, or in other communications which may be in writing, by telephone, via the internet or by any other means.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the purposes for which it was collected. Your personal data may be shared with any Fresh Management Solutions employee or associate as is reasonable and necessary for the purposes identified in this document.

Fresh Management Solutions will use data to:

• Deliver services and support you
• Manage those services we provide to you
• Register and administer qualifications with City & Guilds and ILM
• Respond to enquiries and complaints you have about our services
• Make and confirm appointments
• Promote Fresh Management Solutions services and activities, in line with marketing regulations
• Contact you with relevant information, such as news, events and activities
• Process payments
• Carry out equal opportunities monitoring.

On rare occasions, we may need to use your data for other reasons. In this case, we will notify you, explain why we are doing this, and tell you the legal basis which allows us to do so.

We may need to use your data:

• To fulfil a legal obligation
• For establishing and administering a management database
• For internal record keeping
• For marketing
• To complete activities of legitimate interests to Fresh Management Solutions or a third party, where your interests and fundamental rights do not override those interests
• To protect your, someone else’s, or public interests
• Where it is necessary to comply with a legal obligation.

Wherever possible and practical we will anonymise personal data, for example survey results. In this case, it can no longer be associated with, or used to identify, an individual.

WHO DO WE SHARE YOUR INFORMATION WITH?

We sometimes use a range of organisations to help deliver our services to you. Where we have these arrangements we take measures to satisfy ourselves that the organisations are reputable, trustworthy and comply with data protection law.

Fresh Management Solutions will act as a Data Controller for the personal data that third-party services share with us.

Fresh Management Solutions may share statistical data with third parties, but no information from which individuals can be identified. We will not, without your consent, supply your personal information to third parties for direct marketing.

DATA SECURITY

Fresh Management Solutions uses a range of measures to protect the security of your data and prevent unauthorised access, loss, misuse or inappropriate alteration of your data.

We have put in place reasonable physical, electronic and managerial procedures to safeguard and secure personal data. For example, we use:

• Locked cabinets and locked data storage rooms
• Strong passwords
• Password protected accounts/log-ins, databases, documents and programs
• Restricted access to server accessible only by authorised personnel
• Up-to-date virus protection, hardware as well as software including firewalls, and malware software.

We have procedures to deal with a suspected data security breach, which may include notifying you and the Information Commissioner’s Office where we are legally required to do so.

DATA RETENTION

We will retain your personal information (including printed and electronic documents) for only as long as necessary to fulfil the purposes for which we collected it, and to fulfil legal, accounting, employment, and reporting requirements.

Your personal data stored by Fresh Management Solutions will be anonymised or deleted at the point retention expires.

Any information we have collected that we may use for marketing purposes (and for which you have given explicit consent) will be kept with us you until you notify us that you no longer wish us to hold the data.

UPDATING INFORMATION

Fresh Management Solutions has a duty to keep all the information we hold about you up-to-date in line with any amendments you tell us of. As such, please keep us informed of any changes to your personal information by contacting us.

YOUR RIGHTS

GDPR gives you greater control over your data held by Fresh Management Solutions.

1. Privacy Information. Fresh Management Solutions will always inform you about the collection and use of your personal information.
   We will outline the purpose for which we obtain and use your data, the retention periods and who it will be shared with.
2. Subject Access. You have the right to request access to your personal information. If you do this, Fresh Management Solutions will provide you with a copy of the personal information we hold about you to check that:

• we are processing it lawfully
•  it is up-to-date.

3. Correction. If you consider the personal information we hold about you to be inaccurate or incomplete, you can request for us to correct it.
4. Restriction. If you have any concerns about the way Fresh Management Solutions may be using your data, you may request for us to suspend its use while these are investigated. This is known as ‘restriction’. Concerns you may have could include:

• Inaccuracies in the data
• Our reason(s) for processing the data
• Preventing erasure of your information, so that it may be available beyond the time frame established in the Fresh Management Solutions Retention Policy (available upon request).

You should note that restricted data remains stored (but not erased) and may be restricted only for a limited time period.

5. Objection. You have the right to prevent Fresh Management Solutions using your personal data where your particular situation means you object to it being processed. In this case, we may require specific reasons.

We cannot request reasons for your objection to direct marketing.

This data may still be stored, and not erased.

6. Erasure. As part of your ‘right to be forgotten’, you may ask Fresh Management Solutions to delete or remove your personal information where:

• there is no acceptable reason for us to continue processing or to store it
• you have exercised your right to object (see above).

7. Transfer (or Data Portability). This right allows you to request us to move, copy, or transfer your personal data easily from the Fresh Management Solutions IT network to yourself or another network, service, business, etc. We will do so without compromising security or the data usability.

This excludes information stored on paper-based files.

You may express your rights, in writing or verbally, by addressing your request to the us, by:

• Emailing contact@freshmanagementsolutions.co.uk
• Writing to Fresh Management Solutions, The Carlson Suite, Vantage Point Business Village, Mitcheldean, Gloucestershire GL17 0DD
• Calling 01594 546322.

Providing an additional, appropriate security measure, we may need identification or other information to confirm who you are. This will clarify your right to access the data and exercise your rights and avoid incorrect disclosures.

Valid forms of identification may include a passport, driving licence or birth certificate.

Fresh Management Solutions will respond to your request within one calendar month. Normally, no fee will be charged unless the request is excessive.

If we are unable to fulfil your request (for example, a legal obligation), or need to take longer to process your request, we will explain why.

RIGHT TO WITHDRAW CONSENT

Occasionally, we may obtain your consent to collect and process your personal data for a specific purpose.

You have the right to withdraw your consent at any time by contacting us (see Changes to this Notice, below).

After Fresh Management Solutions receives notification that you have withdrawn consent, we will no longer process your information for the stated purpose(s). There may be exceptions where we have another legitimate, lawful basis for doing so, which we will inform you of.

REPORT A CONCERN

If you have a concern about the way your personal information has been handled, complaints can be reported directly to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at:

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone 0303 123 1113

Further information is available online at www.ico.org.uk

CHANGES TO THIS NOTICE

Fresh Management Solutions reserves the right to update and amend this Privacy Notice at any time.

POLICY REVIEW

The company recognises that the implementation of this policy is the responsibility of everyone. We will keep employees informed about their data protection roles and responsibilities.

This policy and its practice will be monitored and evaluated annually to ensure its effectiveness.

Maurice McCartney, Director
March 2023

Website Usage & Cookie Policy

Who we are

Our website address is: https://www.freshmanagementsolutions.co.uk/

Learnlovelookahead.com is a trading name of Fresh Management Solutions Ltd.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.