I'm providing this information for the purposes of UK data protection law. So, the controller of this website and the personal data collected through it is Stewart Room and I'm registered with the Information Commissioner's Office (number ZB612828).

 

Data collection

 

If you need to contact me, you can do so through the contact form. You can also subscribe to my email newsletter.  However, neither form is to be used by people based in the EU or EEA, as I am not targeting services at such people through this website, due to the EU GDPR rules on needing to appoint a "legal representative" in the EU when you're based outside, which are a hassle to comply with. The contact form is only to be used by people who are representing a business or other organisation and it gathers very limited personal data (the only mandatory field on the form is the email address, so that I can send a response, but users have the option to provide their first and/or last name if they want to). Please do not use the contact form to send me information about your personal matters, because I cannot provide a response, so I do not want to collect your data. The newsletter asks only for your email address and while it is aimed at people representing a business or other organisation, I am happy for individuals to subscribe, provided that they don't mind receiving what amounts to "marketing" information (but I do not offer services to individuals).

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Purpose and legal basis

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If your email address contains your name, then it will be personal data, as is your first and last name, if you choose to supply them on the contact form. The purpose for my use of the information provided through the contact form (that use is called "processing" under data protection law) is to be able respond to your inquiry. I also need to tell you the "legal basis" that I rely upon for this purpose, which is "legitimate interests", in that it is legitimate for me to provide a response to someone who makes an inquiry.

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The purpose for obtaining your email address through the newsletter subscription form is to provide you with the information that you have requested. However, under data protection law the purpose of sending a newsletter is marketing.  The legal basis for processing this information is consent and you can opt-out from receiving newsletters at any time by following the link in them, or by contacting me through the contact form.

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Sharing your information

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Next, let me tell you about whom I share data with. The answer is with no-one as a matter of course. However, if you reach out about a professional, paid engagement, or about the use of the free services that are mentioned on the home page, I will have to share your inquiry with DWF, my law firm, at some point. Similarly, let's say that you want me to speak at an event; I will need to record that in my law firm's diary even if it's not a paid engagement. However, I won't share your information as a matter of course with my law firm.  For example, let's say that you're an academic writing from a University and you want to bring some research to my attention, I'll regard that as part of my extra-curricular, academic life, so I won't necessarily need to share your information with my law firm. As a rule of thumb, if you contact me about support that is usually provided by a professional services firm (whether its paid or unpaid) and I agree that it is something that I can help you with, I will have to share your information with my law firm.  

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If I do share you information with my law firm, its privacy notice will then apply. 

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Finally, let me tell you about Wix.com. Wix provides me with web hosting services and I have used their applications to design and build this site. Therefore, all forms are stored within Wix's hosting environment, which means that they are a "processor".  Wix's user agreement that I accepted on signing-up for their services addresses all of the rules relating to the use of processors.  You can read more about this here.

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Retention periods

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I don't intend to keep contact forms for long, as I will usually delete them once they've been dealt with. However, if we end up in a continuing dialogue between us, then I'll retain them for at least the length of the dialogue. I will also keep your email address for as long as we have meaningful relationship.  I will only retain your email for delivering the newsletter for as long as you are a current subscriber. 

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International transfers

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Wix uses data centres in the USA, Ireland, South Korea, Taiwan and Israel. Apart from Taiwan, all of these countries are covered by UK "adequacy regulations", meaning that it's fine for my website to be hosted there. For transfers to Taiwan, this is covered by standard contractual clauses. 

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Your rights

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People who provide their personal data to a controller like me have various statutory rights. These provide you with access to your data and rights to erasure, restriction of processing, data portability and to object to processing. You can find out more about these rights on the Information Commissioner's website. You also have the right to complain about me to the Commissioner. 

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Cookies

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Cookies are small text and data files that are stored in your web browser, which means that they can be accessed and read by a website that placed them there. They can be used for various purposes, such as to ensure the security of a website, or to enable functionality (such as the use of online shopping carts), or to monitor the performance of website, or to track your activities online (including to serve you with targeted advertising that is based on a profile of your habits). 

 

The general rule is that cookies cannot be set on a person's browser or computer without their prior consent, unless they are "strictly necessary for the provision of an information society service requested by the subscriber or user". This website uses the word "essential" to describe the "strictly necessary" cookies, which you should have noticed when you first visited it and which will see from the "cookie settings" widget at the bottom left hand corner of the site. If you click on the "cookie settings" link, you will see a preference centre with a series of sliders/ toggles. You can toggle all marketing, functional and analytics cookies for off, but the essential ones are always set to on. 

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This website does use some essential cookies, which are set by Wix, the website host. If you click on the padlock icon in the URL address bar, you can find out what these cookies are.  Wix also provides this overview of the essential cookies that they use, identifying their name, purpose, duration and type.

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EU and EEA issues

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I am not offering any services to people in the European Union or the wider European Economic Area, nor am I monitoring the behaviour of any people in the EU or EEA. Furthermore, the contact form should not be used to seek support with, or to provide me with information about, personal matters.  Likewise, the newsletter is not for use by people in the EU or EEA. Therefore, the European General Data Protection Regulation (GDPR) does not apply to this website and so I have not appointed a European Representative.

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I'm really sorry about this Europe. Brexit broke my heart and its nothing personal. 

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