Warwick Economics and Development

Data Subject Rights Policy – 12.01.26

Warwick Economics & Development Ltd. (WECD, www.w-ecd.com) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of those involved in research and consultancy projects we work on and will only collect and use personal data in a lawful and transparent manner, as set out in the WECD Privacy Policy (shared with you alongside this Policy).

As a ‘data subject’ you have a number of rights under the law with respect to our use of your personal data. This policy explains those rights and how to exercise them.

1. Information About Warwick Economics & Development Ltd

Warwick Economics & Development Ltd. (WECD) registered in England and Wales under company number 07531279.

Registered address: Grosvenor House, 11 St Paul’s Square , Birmingham B3 1RB

VAT number: 116732721

Email address: contact@w-ecd.com

Telephone number: 0121 7529881

Postal address: Grosvenor House, 11 St Paul’s Square , Birmingham B3 1RB

Representative: Georgia Siora

Email address: gsiora@w-ecd.com

Telephone number: 07771 756385

Postal address: Grosvenor House, 11 St Paul’s Square , Birmingham B3 1RB

WECD’s Data Protection Registration No is: ZA043825 (as registered with the UK Information Commissioner’s Office)

WECD’s Cyber Essentials Certification is: https://registry.blockmarktech.com/certificates/32a39e16-e5fc-489f-a4d2-3dff21325d93/?source=email

2. What Does This Policy Cover?

Under data protection law in the UK, including key legislation such as the UK GDPR and Data Protection Act 2018 and any successor legislation, (collectively, “the Data Protection Legislation”) individuals have important rights designed to protect them and their personal data.

This Policy sets out those rights, explains them in clear terms, and provides guidelines on how to exercise them.

3. What Is Personal Data?

Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

In simpler terms, personal data is any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that WECD use is set out in our WECD Privacy Policy (shared with you alongside this Policy).

4. What Are My Rights? (Summary)

The UK GDPR sets out your key rights as a ‘data subject’ as follows:

a. The right to be informed;
b. The right of access;
c. The right to rectification;
d. The right to erasure;
e. The right to restrict processing;
f. The right to data portability;
g. The right to object;
h. Rights in relation to automated decision-making and profiling.

The following sections of this Policy explain each right in more detail. If you have any questions about any of your rights under the Data Protection Legislation, or require more detailed information, please contact the WECD Data Protection Officer at DPO@w-ecd.com, the Information Commissioner’s Office, or your local Citizens Advice Bureau.

5. The Right to Be Informed

You have the right to be informed about WECD collection and use of your personal data. The information WECD provide must include details of the purpose or purposes for which your data is used, how long WECD keep it, and who (if anyone) it will be shared with.

This important privacy information is provided in WECD Privacy Policy. Additional information about your rights is also provided here, in this Policy.

If WECD collect data directly from you, this privacy information will be provided at the time it is collected. We will ask you to read our Privacy Policy and indicate that you have read it and accepted it when receiving our email to participate in our projects.

If WECD collect data about you from a third party, this privacy information will be provided to you as soon as possible and in any event no later than one month after WECD have obtained that data.

6. The Right of Access

This right, also known as ‘subject access’ gives you the right to obtain a copy of any personal data that WECD hold about you as well as other supporting information.

This right is designed to help you understand how and why WECD use your data, and to check that we are using it lawfully.

You can exercise this right by making a ‘subject access request’. A subject access request can be made orally or in writing and although the more detail you can provide, the easier it will be for us to respond quickly, there is no prescribed format for such requests. Please email DPO@w-ecd.com.

WECD are required by law to respond to a subject access request within one calendar month from receipt of proof of identification. We may also need to ask you for further information to understand the scope and nature of your request, and if we do so, the time limit for our response will be paused until you provide the necessary clarification. In certain limited cases, such as where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for a subject access request. For ‘manifestly unfounded or excessive’ requests, however, we may charge a fee.

7. The Right to Rectification

Under the Data Protection Legislation, you have the right to have inaccurate personal data corrected, or incomplete personal data completed.

Where we act as data controllers, we are required to take all reasonable steps to ensure that personal data WECD hold is accurate and, where necessary, kept up-to-date. Your right to rectification is closely tied to this obligation.

You can exercise this right by contacting us (DPO@w-ecd.com or gsiora@w-ecd.com) and asking for your data to be rectified if you believe it is incorrect, out-of-date, or incomplete. Requests for rectification can be made orally or in writing.

WECD are required by law to respond to a request for your personal data to be rectified within one calendar month of receipt. In certain limited cases, for example, where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for having your personal data rectified.

8. The Right to Erasure

This right is also known as the ‘right to be forgotten’ and gives you the right to have your personal data deleted (or ‘otherwise disposed of’ if, for example, it is kept in paper records rather than electronically).

You can exercise this right by contacting us (DPO@w-ecd.com or gsiora@w-ecd.com) and asking for your data to be erased. Requests for erasure can be made orally or in writing. We are required by law to respond to a request for your personal data to be erased within one calendar month of receipt. In certain limited cases, for example, where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for having your personal data erased.

Please note that the right to erasure is not an absolute right and there are certain circumstances set out in the Data Protection Legislation in which the right does not apply. For example, WECD may not have to erase your personal data if WECD need it to comply with a legal obligation. If any of these circumstances apply, WECD will explain why your personal data cannot be erased when responding to your request for erasure.

9. The Right to Restrict Processing

You have the right to request the restriction or suppression of your personal data. In practice, this is an alternative to having your personal data erased. This means that you can limit the way in which WECD use your personal data, while still allowing us to retain it.

Please note that the right to restrict processing is not an absolute right and only applies in certain circumstances as follows:

a. You have contested the accuracy of your personal data and we are verifying the accuracy of it;
b. Your personal data has been processed unlawfully and you want us to restrict processing rather than erasing your personal data;
c. WECD do not need the personal data any more, but you need us to keep it in order to establish, exercise, or defend a legal claim; or
d. You have exercised your right to object (see Part 10, below), and we are considering whether WECD legitimate grounds for processing your personal data override your right to object to us using it.

When processing is restricted, WECD cannot do anything with your personal data other than store it unless we have your consent to do so or unless one of the following applies:

a. WECD need to use your personal data in the establishment, exercise, or defence of legal claims;
b. WECD need to use your personal data in order to protect the rights of another person; or
c. Important public interest reasons justify using it.

You can exercise this right by contacting us (DPO@w-ecd.com or gsiora@w-ecd.com) and asking for the processing of your data to be restricted. Requests for the restriction of processing can be made orally or in writing.

We are required by law to respond to a request to restrict the processing of your personal data within one calendar month of receipt. In certain limited cases, for example, where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for having the processing of your personal data restricted.

10. The Right to Data Portability

Where we are processing your personal data either with your consent and we are using automated means of processing (i.e. not using paper files), you have the right to obtain a copy of your personal data in a commonly-used format for use with another organisation. You can also request that WECD send your personal data directly to another organisation.

This right is designed to enable you to easily move, copy, or transfer your personal data from one organisation’s IT system to another organisation’s IT system in a safe and secure way, without affecting its usability.

Please note that this right only applies to personal data that you have provided to us. It does not include additional data that WECD may create based upon the data you have provided or to data that has been anonymised. In some cases, more personal data relating to you may be available under your right of access.

You can exercise this right by contacting us (DPO@w-ecd.com or gsiora@w-ecd.com) and asking either for a copy of your personal data for use with another organisation, or for your personal data to be transferred to that organisation. Requests can be made orally or in writing.

We are required by law to respond to your request within one calendar month of receipt. In certain limited cases, for example, where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for exercising your right to data portability.

11. The Right to Object

Where we are processing your personal data either on the basis of WECD ‘legitimate interests’ [,in the exercise of official authority vested in WECD or in the performance of a task carried out in the public interest – to explain], you have the right to object to us processing your personal data.

You also have the absolute right to object to us using your personal data for direct marketing purposes. If you object to us using your personal data for direct marketing purposes, your right to do so is absolute and WECD have no grounds on which to refuse.

If you object to us using your personal data either on the basis of WECD ‘legitimate interests’ [, in the exercise of official authority vested in WECD or in the performance of a task carried out in the public interest – to explain which one applies], please note that your right to do so is not absolute. When making your request to exercise this right, you must give specific reasons for your objection based upon your particular situation. WECD can continue using your personal data if WECD can demonstrate ‘compelling legitimate grounds’ which override your interests, rights, and freedoms; or if the processing is necessary for the establishment, exercise, or defence of legal claims. Additional limitations apply if your personal data is being processed for research purposes.

You can exercise this right by contacting us (DPO@w-ecd.com or gsiora@w-ecd.com) and stating your objection to the processing of your personal data for the relevant purpose or purposes, providing an explanation if required (see previous paragraph). Objections to processing can be made orally or in writing.

We required by law to respond to your request within one calendar month of receipt. In certain limited cases, for example, where your request is complex or you have made multiple requests, this period may be extended by up to two months; however, you will be kept informed at all times.

There is not normally a fee payable for exercising your right to object.

12. Automated Decision-Making

WECD do not carry out automated decision-making (i.e., making a decision using automated means only, without any human involvement) using your personal data, as described in WECD Privacy Policy. If this position changes, we will inform you immediately.

You have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal or ‘similarly significant’ effects.

You have the right to challenge decisions made in this way and can:

a. Request human intervention;
b. Express your own point of view; and
c. Obtain an explanation about the decision and challenge it.

There is not normally a fee payable for exercising your rights relating to automated decision-making.

13. Exercising Your Rights

To exercise any of your rights as a data subject, please contact us (DPO@w-ecd.com or gsiora@w-ecd.com) via email as noted here or:

  • Post: Two Snow Hill, Birmingham, B4 6GA
  • Telephone: 07771 756385

When contacting us to exercise your right of access, please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the information being requested

When contacting us to exercise your right to rectification, please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the information you wish to have rectified
  • (Where relevant) any information that supports your request or otherwise provides evidence of the need for rectification

When contacting us to exercise your right of erasure, please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the information you wish to have erased
  • (Where relevant) any information that supports your request or otherwise justifies the need to have the data erased

When contacting us to exercise your rights to restrict processing or to object to processing, please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the processing you wish to restrict or object to
  • Details of why you want the processing to be restricted or why you object to it
  • (Where relevant) any information that supports your request or otherwise provides evidence of the need for processing to be restricted or stopped

When contacting us to exercise your right to data portability, please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the personal data you wish to use with another service or organisation, also stating whether you require a copy of that data for yourself or whether you would like us to transfer it directly to the other service or organisation
  • (Where relevant) any information that supports your request

When contacting us to exercise your rights relating to automated decision-making (including profiling), please provide:

  • Your full name
  • Your address
  • Your telephone number
  • Your email address
  • Details of the decision that you wish us to explain or review, also stating whether you would like us to explain the decision, if you are requesting human intervention, wish to express your own point of view about the decision, or wish to challenge the decision
  • (Where relevant) any information that supports your request

14. WECD Acknowledgement and Response

WECD will always respond quickly to your request to exercise any of your rights in relation to your personal data. WECD will acknowledge receipt without undue delay and will provide a complete response to your request as quickly as possible. Normally, as stated above, this will be within one calendar month of receipt of your request.

If additional time is required, WECD will contact you within the first 14 days to explain why the delay is necessary.

15. Your Right to Complain

If you have any cause for complaint about WECD use of your personal data, or about WECD handling of your request to exercise your rights under this Policy, you have the right to lodge a complaint with the Information Commissioner’s Office.

WECD would welcome the opportunity to resolve your concerns myself directly. Therefore, please contact me first using the details set out above in Part 13 (gsiora@w-ecd.com).

16. Changes to this Policy

WECDmay change this Policy from time to time. This may be necessary, for example, if the law changes, or if WECD change WECD business in a way that affects personal data protection. This Policy is reviewed on an annual basis (unless legislation requires an earlier review).

Any changes will be made available on our website. This Policy was last reviewed and last updated on 6 January 2024.

Any questions about the interpretation and operation of our policies are addressed to the Data Protection/Information Officer in the first instance at DPO@w-ecd.com.

Georgia Siora, the company’s Managing Director, is ultimately responsible for ongoing compliance with the legislation and can be contacted at: gsiora@w-ecd.com

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