Privacy Policy

LAST UPDATED 30/09/2020

MoNo CyberConsulting Ltd (MoNo) cares about keeping personal data safe. This includes the way in which we collect and process personal data legally and compliantly, and safeguarding privacy. By personal data we mean any data which identifies you as an individual. 

We are committed to complying with data protection and privacy laws and we will ensure that any organisations we may work with in the future, are too. Our Privacy Policy explains how we use and look after your personal data and sets out your privacy rights. 

We recognise that data protection and privacy is an ongoing responsibility, and so we will, from time to time, update this Privacy Policy as we proactively keep up to date with changes in the law. We encourage you to review this policy every now and again to ensure that you are aware of any changes to it. 

Where there are significant changes to the Privacy Policy which may affect how we process your personal data, we may contact you to make you aware of the changes.

HOW WE COLLECT YOUR PERSONAL DATA

MoNo is the Data Controller for all personal data we collect. This means we decide what personal data we need you to provide and are responsible for communicating to you why we have collected your personal data. 

We might collect your personal data via the following channels:

• When you provide it directly to MoNo, by calling, texting, emailing, or writing to us
• When you provide it to us when you express an interest in our service
• When you get in touch or connect with us via our social media channels
• When you have given Third Parties consent to share it with us 
• When you visit the MoNo website
• When you contract to use MoNo services 

You may be sharing your personal data with us at various stages of your MoNo journey: from visiting our website to find out more about us, to expressing an interest in the services we offer, or to sign up to utilise MoNo service.

WHAT PERSONAL DATA DO WE COLLECT?

Your personal data is any information which can be used to identify you. Depending on where you are in your journey with us; we might collect: 

• your name 
• telephone/mobile number 
• email address
• postal address
• your date of birth

HOW WE PROCESS YOUR PERSONAL DATA

MoNo processes the personal data you provide to us to discuss the provision of our services to you, any contractual agreement between us, and to inform you about MoNo events and other benefits or opportunities associated with the MoNo experience. We may also use this information to help us in understanding any specific service needs and interests clients may, to better tailor products and services to them, and to support ongoing service improvement.

Here are some of the ways we may use your personal information:

• To contact you to inform you more about our service, or about becoming a client
• To understand your needs and interests to better tailor products, information and services to you
• To provide you with information about MoNo services which you may have requested, or which we consider to be of relevance to you
• To respond to your enquiries, complaints, or requests
• To promote our products and services e.g. MoNo events, publications, and other services
• To conduct original research to help us evaluate and improve our services 
• To improve the services offered on our website

We might also receive personal data about you from external data sources including publicly available websites, databases or other third parties where they have a lawful basis to disclose your personal data to us - for example, if you have expressed an interest in cyber consultancy services and agreed that your personal data can be shared with us. We may combine this with personal data we already hold about you for the purposes of pursuing our goals and functions as set out in legislation. This helps us to update, expand, and analyse our records and identify new prospects and provide products and services which may benefit you.

THE LAWFUL BASIS WE USE TO PROCESS YOUR PERSONAL DATA

We will process your personal data under one or more of the following lawful bases:

Where you have given us clear, informed consent

· We will ask for your informed consent to process your personal data. In doing so, we will use clear plain language to tell you what we will be doing with your personal data so you can fully understand what you are consenting to. 

· We will also explain your right to withdraw your consent at any time, and how you can do that.

· We will only use the personal data you have provided for the purpose we have obtained your consent for. 

The processing is necessary for the performance of a task carried out in the public interest

The processing is required for the performance of a contract 

Were we have a legal obligation to process the data

· We may need to share your personal data in exceptional circumstances to comply with the law (i.e. the common law or a statutory obligation). For example, we may be obliged to share personal data with law enforcement agencies or court where it might assist them with an investigation or where we are compelled to by a Court Order or any matter regarding national security (please note these examples are not exhaustive).

The processing is necessary for your vital interest or the vital interests of others

· We have a responsibility to ensure safe operations of our clients and their staff. Therefore, we may not always be able to keep information you provide to us as confidential. If we consider that you have given us information about yourself or another person within your organisation which puts anybody or yourself at risk from harm, then we may need to tell someone who can help, for example, the Information Commissioners Office (ICO).

We have a genuine and legitimate reason and we are not harming any of your rights and interests

· There may be activities that we carry out that are in the legitimate interests of MoNo, or which we consider are in your legitimate interests. Whenever we use this justification, we will carry out a balancing exercise to ensure that we consider the impact on your rights and freedoms and do not override these. Some examples of how we might process your personal data under legitimate interests are:

o sending you direct marketing

o fraud prevention

o ensuring network and information security, or

o business to business contact.

WHEN WE SHARE PERSONAL DATA WITH OTHERS

MoNo does not sell your personal data to any third parties.

We may share your personal data with other third party suppliers, such as approved contractors who provide services to MoNo if they support our work, or our contract with you. If this is required in the future, we will carry out an assessment of prior to engaging in a contractual relationship with them. Any third party suppliers we may work with, will be required to take appropriate security measures to protect your personal data in line with our policies. We will not allow them to use your personal data for their own purposes and will only allow them to use your personal data for specified purposes and in accordance with our instructions.

We may also share your personal data with relevant government bodies and fraud detection organisations or law enforcement agencies under special circumstances as listed above.

Where your personal data is shared with third parties, we will share the minimum amount necessary.

HOW THIRD PARTIES COLLECT YOUR DATA

The MoNo website interacts with social media platforms including Facebook, Twitter, and others. If you choose to ‘like’ or share information from the MoNo website through these services, you should review the privacy policy of that service. Interacting with a like or share interface on our website may allow your activity to be connected to your personal page or profile on the given platform.

HOW WE USE YOUR PERSONAL INFORMATION FOR RESEARCH AND ANALYTICS.

MoNo may also use your personal data to optimise and improve its services, by performing analysis and extracting insight from that analysis. We will take great care in ensuring that any analysis is in our client’s interest.

YOUR RIGHTS

You have the following rights under the data protection laws:

• Right to be informed - told in a clear and transparent way how we process your      personal data
• Right of access - you can request a copy of the personal data we hold about you       
• Right of rectification - you can update or amend the personal data we hold about you if it is incorrect
• Right to restrict processing - you can ask us to stop using your personal data
• Right to be “forgotten” - you can ask us to delete your personal data from our records
• Right to object - you can object to the processing of your personal data for marketing purposes 
• Right to data portability - you can obtain and reuse your personal data for your own purposes
• Right related to automated decision making and profiling - you can request to not be subject to a decision when it is based on making a decision solely by automated means without any human involvement and/or automated processing of personal data to evaluate certain things about an individual

If you would like to make a request for any of the above, please submit it to info@mono-cyberconsulting.co.uk marking it clearly in the subject field, Data Protection.

MoNo MARKETING AND YOUR CHOICES.

We would like to tell you about what we do and send you information about our news and updates, and promotions from time to time. 

We will not use your personal data to send you marketing communications if you have told us that you do not want to be contacted for this purpose.  
You can change your marketing preferences, such as the method by which we contact you (email, phone or text), or opt out of receiving marketing communications from us at any time by emailing us at info@mono-cyberconsulting.co.uk marking it clearly in the subject field, Marketing.

Where you choose to opt out or unsubscribe from our emails and texts we will stop sending you marketing communications immediately.

USE OF THE MoNo WEBSITE

The MoNo website collects, and stores safely, certain personal information automatically. The personal information may include your internet protocol (IP) address, the region or general location where your computer or device is accessing the internet, and other usage information about the use of the MoNo website. We use this information to help us design our site to better suit our users’ needs. 

The MoNo website is constructed using a ‘Go Daddy’ template. This organisation may use cookies on our website. For more information please visit their website (Go Daddy) for further information.

TRANSFER OF PERSONAL DATA OUTSIDE THE EU

The personal data we collect is stored securely in one or more databases hosted by third parties located within the European Economic Area (EEA), or in locations which have demonstrated they have adequate standards of data protection compliance, or where we have implemented safeguards to ensure that your personal data is safe and secure.

This Privacy Policy is being kept under review as we approach the end of the Brexit Transition Period (31st December 2020) and will be updated as appropriate.

HOW WE PROTECT YOUR PERSONAL DATA

To help protect your privacy, we maintain physical, technical, and administrative safeguards. These safeguards are designed to prevent unauthorised access, disclosure, use and modification of data. We regularly review our security procedures and consider appropriate new technologies and methods.

We continually update our skills in all areas of cyber security, especially about the importance of confidentiality and maintaining the privacy and security of your information, and your personal data is only accessed by appropriately trained staff.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will ensure that your personal data is only kept for as long as is necessary for the purpose we collected it from you, and that it is securely destroyed in accordance with best practice. Where possible we will inform you of how long we will retain the personal data you are providing to us.

In some cases, we may be legally required to hold on to some personal data for longer in order to fulfil statutory obligations e.g. where we are required to keep it under the law.

WHO IS THE DATA PROTECTION OFFICER?

MoNo has appointed an internal Data Protection Officer for you to contact if you have any questions or concerns about our personal data policies or practices. Their name and contact information are as follows:

Martin Fell

mailto:martin.fell@mono-cyberconsulting.co.uk

WHO IS THE DATA PROTECTION REGULATOR?

Further information and advice about UK data protection law and compliance is available from the Information Commissioner's Office. You can contact them using the details below:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow, Cheshire
SK9 5AF
Phone: +44 (0) 01625 545 745
Website: www.ico.org.uk