Our privacy promise is that we will aim for best practice in the handling of personal information, by following the privacy principles below unless authorised or required by law to depart from them.
A feature of our social media ‘sharing’ buttons that we wish more websites would use
We want to protect your privacy when you read our website. Lots of websites, including our blog pages, feature social media ‘sharing’ buttons – you know, the ‘share’ icon for Facebook, the ‘tweet’ icon for Twitter, and all the rest. We love it when our readers share our blogs with a wider audience! But we don’t think you should be tracked just for reading our blogs.
In case you didn’t already know, that’s exactly what the default social media ‘sharing’ buttons on most websites do. They allow Facebook, Twitter, LinkedIn etc to track their users when they look at web pages, even if you don’t click on the ‘sharing’ buttons. Here at Salinger Privacy we think that’s pretty appalling. You should be able to read in private! So when we wanted to add ‘sharing’ buttons to our website, we hunted around to find an alternative.
Happily, we found and implemented these ‘do not track’ social sharing buttons, which come as an open-source, free plugin for WordPress from Privacore, the people working on the findx privacy-protecting search engine.
So now you can read our blogs in peace. Unless, of course, you really do want to share our wit and wisdom with the wider world, in which case, be our guest.
If you are in charge of a website, we’d like to encourage you to do the same.
The types of personal information we hold
We hold personal information about our own staff, as well as the contact details of suppliers and other types of professional associates.
We also hold the contact details of ‘customer contacts‘, by which we mean individuals with whom we have some form of customer relationship: individuals who have purchased a Compliance Kit, an eLearning module, eBook or other publication from us; been a past training or consulting client; registered or been waitlisted for a training course, webinar or other type of event; downloaded a free Handbook from us; made an enquiry about our publications, training or consulting services; and/or subscribed to our eNews and/or Product News email newsletters.
Our third party service providers
The contact details of our customer contacts (see definition above) or other type of business relationship (including our staff, and individuals who work for our clients, suppliers and others) may be held offshore, including ‘in the cloud’, by our third party service providers.
Our third party service providers are currently Microsoft Office 365 (address book for professional contacts), Xero (accounts information for clients and suppliers), MailChimp (names and email addresses of customer contacts who receive our eNews and/or Product News newsletters), TryBooking (names, email addresses, telephone numbers / dietary needs / special needs (where applicable for face-to-face training) of individuals who have purchased tickets to our training events or webinars, or who have registered to attend free events), and PayPal (names and email addresses of individuals who have purchased Compliance Kits, eBooks or eLearning modules, or who pay for consulting or training services by credit or debit card).
Financial information about individuals who have purchased tickets to training events or webinars is held and processed on our behalf by TryBooking. Financial information about individuals who have purchased Compliance Kits, eBooks or eLearning modules, or who have paid for consulting or training services by credit card, is held and processed on our behalf by PayPal. We do not know, or have access to, any purchaser’s debit or credit card or bank account information.
We use Google Analytics to measure how many people visit our website, how they found our site (e.g. organic search, clicking on a link from a tweet, or via an ad), which pages on our site they view, and whether they go on to purchase or download one of our products. This data is not shared with any other third party besides Google technical support (and then only if we require it). While Google Analytics does not directly identify users, as mentioned above we do collect the name and email address of individuals who download or purchase our products online.
We use MS Teams to host ‘live virtual’ meetings with clients and their stakeholders, and to run training events and webinars. For large free webinars we may use Zoom as an alternative to MS Teams. Participants who use in-event functionalities like Chat or Q&A may have their information collected by the hosting platform.
We use SurveyMonkey to seek feedback from people who have attended our training events and webinars. While we design our surveys to avoid collecting information that would allow us to identify survey respondents, and we use pro-privacy settings within the survey platform (e.g. we do not collect IP addresses), in some cases it may be possible for us to identify survey respondents from the content of survey responses. We make this clear at the point of collection for each survey, by warning respondents not to inadvertently reveal identifying information about themselves via their survey answers.
Limiting our collections
We will only collect personal information if:
- it is for a lawful purpose that is directly related to one of our functions, and
- it is reasonably necessary for us to have the information
How we will collect personal information
We will collect personal information directly from the individual concerned unless it is unreasonable or impractical
We will not collect personal information by unlawful means
We will not collect personal information that is intrusive or excessive
We will take reasonable steps to ensure that the personal information we collect is relevant, accurate, up-to-date and complete
When collecting personal information, we will take reasonable steps to inform the person:
- what part of Salinger Privacy will hold and/or have access to their personal information
- what it will be used for
- what other organisations (if any) routinely receive this type of personal information from us
- how the person can access their personal information held by us
- whether the collection is required by law, and
- what the consequences will be for the person if they do not provide the information to us.
We will enable anyone to know, upon request, whether we are likely to hold their personal information, and if so:
- what type of information we hold about them
- the purposes for which it will be used, and
- how they can access their own personal information.
We will take reasonable security measures to protect personal information from loss, unauthorised access, use, modification or disclosure.
We will take reasonable steps to ensure personal information is stored securely, not kept longer than necessary, and disposed of appropriately.
Access and amendment
We will allow people to access their personal information without unreasonable expense or delay
We aim to respond to requests within 30 days
We will only refuse access where authorised by law, and we will provide written reasons
We will allow people to update, correct or amend their personal information where necessary, to ensure it is accurate, relevant, up-to-date, complete or not misleading
Where possible, we will notify any other recipients of any changes
Before using or disclosing personal information, we will take appropriate steps to ensure that the information is relevant, accurate, up-to-date, complete, and not misleading
Use and disclosure
We will use or disclose personal information only for the primary purpose for which it was collected, unless one of these apply:
- the person has consented
- it is for a directly related secondary purpose within the reasonable expectations of the person (for example, to issue a receipt or answer an enquiry about an online purchase; or to add a new customer contact to our Product News mailing list), or
- it is to a related or associated company for the purpose of providing a service.
It is not practicable for us to provide anonymous services, although subscribers to our email newsletters, and purchasers of our online products, may of course use pseudonyms.
Our Privacy Officer
Our Privacy Officer is our Principal, Anna Johnston. Please contact us to get in touch.