v2.3 20_10_2022

Contents

  1. Introduction
  2. Who we are
  3. Companies and websites within scope
  4. Collection of personal data
  5. Lawful basis for the processing of personal data
  6. Storage of personal data
  7. Security measures
  8. Your rights as a data subject
  9. European Union representation
  10. Contact us
  11. Complaints

 

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we explain how we collect, use and protect your personal data.

We also explain your rights with regard to your personal data and how you can exercise those rights.

 

2. Who we are

GRC International Group PLC is the parent company for a number of organisations, including IT Governance Ltd and GRCI Law Limited. The full list of organisations that fall into the scope of this notice can be found in section 3 below, along with their associated websites.

GRC International Group PLC is the data controller for all the organisations within the group that are covered by this notice. This means that GRC International Group PLC determines what data is collected by each organisation within the group, how this data is going to be used and how this data is protected.

Our registered office address is:

GRC International Group PLC

Unit 3, Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely
Cambridgeshire
CB7 4EA
United Kingdom

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at privacy@grci.group.

 

3. Companies and websites within scope

The following companies and websites are within the scope of this privacy notice:

GRC International Group PLC www.GRCI.group
DQM GRC (Data Quality Management Group Ltd) www.dqmgrc.com

IT Governance Ltd

www.itgovernance.co.uk
www.itgovernance.asia (Singapore)
IT Governance Europe Ltd www.itgovernance.eu
IT Governance Inc www.itgovernanceusa.com (US)
IT Governance Publishing Ltd www.itgovernancepublishing.co.uk
GRC eLearning Ltd www.grcelearning.com
GRCI Law Limited www.grcilaw.com
Vigilant Software Ltd www.vigilantsoftware.co.uk

 

We consider these predominantly UK-based websites; see section 6 below for more information on our limited non-UK data processing.

This notice also covers any additional personal data collected in the following online web applications:

IT Govnernance Cyber Essentials portal https://ces.itgovernance.co.uk/
GRC eLearning management system www.users.grcelearning.com
CyberComply, and all its modules www.cybercomply.co.uk
DocumentKits www.documentkits.com
GDPR.co.uk www.gdpr.co.uk

 

It includes personal data that is collected through our websites, by telephone, through LiveChat and through any related social media applications.


4. Collection of personal data

We collect personal data from you for one or more of the following purposes:

  1. To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
  2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of products and/or services.
  3. To fulfil a contract that we have entered into with you or with the entity that you represent. In these circumstances, it may be your entity, rather than yourself, that has provided us with your personal data.
  4. To provide access to trial software and to deliver a range of free material on request.
  5. To ensure the security and safe operation of our websites and underlying business infrastructure.
  6. To manage any communication between you and us.

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

  • Technical information, including the IP address used to connect your device to the Internet.
  • Your login information, browser type and version, time zone setting, browser plugin types and versions.
  • Operating system and platform.
  • Information about your visit, including the URL clickstream to, through and from our site.

From time to time we may use technologies, such as tracking pixels (also called 1x1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing to your needs so we can send you more relevant emails. It also helps us to identify subscribers who are not engaged with our marketing emails so we can remove them from our send lists.

Our Cookie Policy, which can be viewed from the homepage of each of our websites, describes in detail how we use cookies.

In section 8 below, we identify your rights in relation to the personal data that we collect and describe how you can exercise those rights.

Third-party processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital marketing service providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf. Such activity may result in the GDPR-compliant processing of personal information. Our appointed data processors include:

(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view its privacy policy here: http://sopro.io. Sopro is registered with the ICO Reg: ZA346877; its data protection officer can be emailed at: dpo@sopro.io.
 

5. Lawful basis for processing personal data

The table below describes the personal data we collect and the lawful basis for processing this data. The organisation of our business architecture, accounting and systems infrastructure and compliance means that all personal data is processed on common, group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

 

Purpose of collection

Information category

Data collected

Specific use

Lawful basis for processing

Data shared with?

Retention period

1. To provide you with information

Subject matter information

Name, company name, geographic location, email address, business sector.

To provide appropriate online or email information about products and services that you have requested.

Contractual fulfilment

Internally only.

Maximum eight years from the date the information is collected.

Six months if a marketing email is left unopened.

To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.

Legitimate interest

Internally only.

Telephone number.

Follow-up to ensure requested information meets needs and identify further requirements.

Legitimate interest

Internally only.

Personal contact information as provided through website forms or at trade shows, or via any other means.

General mailing list subscription.

Consent

Internally only.

2. Transactional information

Transaction details

Name, physical address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery.

To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.

Contractual fulfilment

Internally only.

Maximum eight years from the date of the performance of the contract.

Six months from the date the data subject has input personal information but has not proceeded with a transaction.

Eight years for VAT records from the performance of the contract.

For accounting and taxation purposes.

Statutory obligation

Internally and professional advisers.

Documentation should any contractual legal claim arise.

Legitimate interest

Internally and professional advisers.

Payment card data

PAN (primary account number), cardholder name, service code, expiration date.

To fulfil purchase requests using payment cards.

Contractual performance

Payment card companies, in line with the
PCI DSS.

Only retained while authorisation is pending.

3. Fulfilment information

Fulfilment data

Name, dietary requirements.

Appropriate catering arrangements for training courses.

Contractual performance

Internally and training venues.

Maximum six years from the date of the performance of the contract.

Name, contact and identification details.

Access to training courses, attendance registers.

Contractual performance

Internally and training venues.

Name, contact and identification details.

Exam attendance, exam results and certifications.

Contractual performance

Internally and external examiners, proctors and certification bodies.

Name, contact details.

Licensing details necessary for allocating and maintaining a licence purchased for use of software and related products, self-paced learning and e-learning.

Contractual performance

Internally and any third parties whose products or services you may have purchased from us.

Name, address(es), email address, contact details.

Actual delivery of products or services, in physical or digital form, that you may have purchased from us.

Contractual performance

Internally and any third-party logistics or supplier companies with which we contract to fulfil these requirements.

4. Security

Security information

Technical information, as described above, plus any other information that may be required for this purpose.

To protect our websites and infrastructure from cyber attack or other threats, and to report and deal with any illegal acts.

Legitimate interest

Internally, and forensic and other organisations with which we might contract for this purpose.

Relevant statutes of limitation.

5. Communications

Contact information

Names, contact details, identification details.

To communicate with you about any issue that you raise with us or that follows from an interaction between us.

Legitimate interest

Internally and, as necessary, with professional advisers.

Relevant statutes of limitation.

6. Product development

Survey data

Names, contact details, identification details.

To develop existing and new products that meet the expectations and requirements of our customers.

Consent

Internally and, where additional consent is given, for marketing purposes.

If anonymised for statistical research, this data may be kept indefinitely.

Where not anonymised, it shall be retained for a maximum of one year.

 

6. Storage of personal data

GRC International Group PLC is a UK-domiciled organisation whose primary offices are in the UK.

  • The majority of our websites and web applications are hosted in the UK and are accessed only by our UK and EU-based staff.
  • Our US website, as identified in section 2 above, is targeted at non-EU and non-UK customers and is accessed by staff located outside the UK. Our US website is the only one of our websites that is also hosted outside the UK. In these instances, we have appropriate contractual and security measures in place to ensure that personal data is protected.
  • Our customer relationship management, marketing and accounting systems are either UK-based or, in cases where this is not true, data transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulation or “EU GDPR”) and may be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA.
  • We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
  • Unless we specifically state otherwise, all these CSPs use UK processing facilities.
  • Personal data supplied to any GRC International Group PLC company for our delivery – as a certification body – of Cyber Essential scheme certifications will be processed by us but controlled by IASME Consortium Ltd. IASME, in its role as controller of the personal data you provide, will control what happens to the data in its possession.
  • Our payment processors and banking arrangements are based in the UK and, for our US website, in the US.
  • We ship and deliver physical products around the world; we therefore use logistics companies that are based outside the UK and operate in other countries. We have appropriate legal and security relationships with those partners.
  • We resell products supplied by organisations outside the UK. This may mean that our resale partners will have access to information about data subjects who purchase their products.
  • We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are in the table in section 5 above.

 

7. Security measures

Our ISMS (information security management system) is certified to ISO/IEC 27001:2013. Our UK business is also Cyber Essentials Plus certified and all our payment card processing is in compliance with the PCI DSS (Payment Card Industry Data Security Standard).

We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

 

8. Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email privacy@grci.group or use the information supplied in the ‘Contact us’ section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

  • The right to be informed
    As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.

  • The right of access
    You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:

    a) The purposes of the processing.
    b) The categories of personal data concerned.
    c) The recipients to whom the personal data has been disclosed.
    d) The retention period or envisioned retention period for that personal data.
    e) When personal data has been collected from a third party, the source of the personal data

    If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or unreasonable expense (which you may have to meet), we will inform you.

  • The right to rectification
    If you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

  • The right to erasure (the ‘right to be forgotten’)
    Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

  • The right to restrict processing
    You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

    a) The accuracy of the personal data is contested.
    b) Processing of the personal data is unlawful.
    c) We no longer need the personal data for processing, but the personal data is required for part of a legal process.
    d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

  • The right to data portability
    You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

  • The right to object
    You have the right to object to our processing of your data under one of the following conditions:

    a) Processing is based on legitimate interest.
    b) Processing is for the purpose of direct marketing.
    c) Processing is for the purposes of scientific or historic research.
    d) Processing involves automated decision-making and profiling.

 

9. European Union representation

For those customers based within the EU, our subsidiary IT Governance Europe Ltd acts as our EU representative. If you wish to exercise your rights under the EU GDPR, or have any queries in relation to your rights or general privacy matters, please email our representative at privacy@itgovernance.eu. Please ensure you include the name of the entity that you have engaged with in any correspondence you send to our representative.

 

10. Contact us

Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed to privacy@grci.group

Alternatively, you can contact us at our global HQ using the following postal address, telephone number or fax number:

GDPR Compliance Manager
GRC International Group PLC
Unit 3, Clive Court
Bartholomew’s Walk
Cambridgeshire Business Park
Ely
Cambridgeshire
CB7 4EA
United Kingdom

Telephone: +44 (0)333 800 7000
Fax: +44 (0)1353 662 667

Our telephone switchboard is open 9:00 am – 5:30 pm GMT, Monday to Friday. Our switchboard team will take a message and ensure the appropriate person responds as soon as possible.

 

11. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the EU. For the UK, this is the ICO (Information Commissioner’s Office), which is also our lead supervisory authority. Its contact information can be found at https://ico.org.uk/global/contact-us/.

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