The Purpose of this privacy statement is to explain how Kreatif Design Limited processes personal data to fulfil its data protection responsibilities. This statement will be supplemented by ‘specific to client’ privacy notices when needed. The scope of this statement covers all related activities by the staff of Kreatif Design Limited referred to as KD for the remainder of this document.

The Role of KD in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the KD privacy manager (PM) to ensure that it is processed in accordance with the latest UK data protection legislation. You can contact the PM using studio@kreatif.co.uk. KD is registered with the Information Commissioner’s Office (ICO).

The personal data processed by KD will be basic contact information for the purposes of responding to general enquiries, business development, preparing contracts and setting up invoices. If KD is not given all of the required personal data, it may result in an incomplete service being provided.

KD’s duty of confidentiality means that KD staff will treat clients’ personal data with due respect and in confidence. It is only disclosed to those that need to know it. KD also expects the same duty of confidentiality of all third parties with whom it shares personal data. KD uses reasonable organisational and technical measures to ensure personal data is kept secure.

KD processes personal data against a lawful basis as described below:

• To respond to your general enquiries and to promote our services, we will use our legitimate interests
• To comply with our legal obligations
• To fulfil our contractual obligations including their prior preparation
• When processing a pre-defined purpose for which your consent has been sought and recorded prior to that processing commencing

In all cases the processing of personal data by KD shall be:

• Processed lawfully, fairly and transparently
• Collected for specified, explicit and legitimate purposes
• Adequate, relevant and limited to what is necessary (and no more)
• Accurate and, when necessary, updated
• Kept for no longer than is necessary
• Processed in a manner that ensures appropriate security.

KD will share personal data, but only when absolutely necessary, with some or all of the following third parties:

• The Inland Revenue (HMRC)
• An accountant appointed by us
• 20i Limited for domain hosting and SSL certificates
• Specified professional consultants in support of the service, notified at the time
• Unspecified recipients but only when compelled to do so for legal reasons

KD operates in a paperless environment where the first line processing takes place on standard office IT equipment based in and around the company’s registered premises. In addition, use is made cloud services such as Microsoft One Drive, Dropbox, Google Drive and a private NAS Server based in the EEA. KD uses Xero accounting.

KD follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:

• Routine correspondence for casual enquiries in emails will be stored for one year
• Service contract related data will be retained throughout the life of the engagement plus another 10 years following the termination of the contract
• Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject
• Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
• By exception, documentation that includes personal data may be retained by KD beyond the schedule, but only for a specific purpose and only when KD believes there is a legitimate interest or a legal obligation to do so

At the end of the retention schedule KD will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that KD allows up to 3 months after the retention schedule to complete the action.

The KD website uses cookies but visitors to the website are asked to consent to non-essential cookies before these are dropped – please see the separate cookie notice.

The KD website links to appropriate business websites of interest. If these are used, you should be aware that the KD has no responsibility for the control, content or handling of your personal data by these other websites.

The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:

• Right to be informed as to how your personal data is being processed by KD – this is done through this statement or specific to customer privacy notices
• Right to access your personal data held by KD which is done by making a ‘Data Subject Access Request’ (DSAR) to the privacy manager
• Right to rectification of your personal data if you believe KD has collected it incorrectly or it needs to be updated
• Right to erasure of your personal data for which KD no longer has a legitimate purpose to process
• Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved
• Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
• Right to object to KD processing your personal data for which it does not have a legal or contractual obligation
• Rights related to automated decision making and profiling (however KD does not use these techniques in its decision making)

Further details on your rights can be found on the ICO’s website: https://ico.org.uk.

Raising concerns, exercising rights or making queries about KD’s processing of personal data can be done by contacting the privacy manager. Please be aware that we will need to determine your identity before responding fully, therefore, you may be asked for proof of ID or other material that, in context, will enable us to confirm your identity. Alternatively, you may wish to contact the ICO directly, using the details provided above.