This page serves as the GDPR Privacy Notice for www.bentasker.co.uk.
The controller of the data collected is Ben Tasker.
You have the right to object to processing, either by objecting to a specific mechanism as described below, or by Contacting Me. If you feel your objection has not been appropriately handled, or that the processing does not have a lawful basis, you also have the right to complain to a supervisory authority.
As an overall summary of the policy - I collect some data in order to run and improve the site, but will not share that data with third parties unless I'm legally compelled to do so.
Where I'm performing a service for you (i.e. you're a customer rather than simply visiting the site), our contract will include sections as needed to cover any additional elements I may encounter whilst working for you.
Compliance with a Legal Obligation
The following data is processed/retained in order to comply with Legal Obligations - GDPR Section 6(1)(c)
If you purchase a product or service from me, then you will have been issued with an invoice containing some or all of the following personal data
- Your Name
- Your Address
- Your Email Address
- Your Telephone Number
A copy of your invoice will be filed with my Tax records, which in order to fulfil HMRC's requirements must be retained for up to 7 years.
Because this data must be available in order to comply with a legal obligation, the GDPR rights of erasure and objection cannot be exercised for this data.
The data is retained on isolated systems with very strong access controls, and will not routinely be passed to any third party. In the event of an audit by HMRC, however, the data may be provided to them when formally requested.
The following data is processed/retained based upon the Lawful Basis of GDPR Section 6(1)(f) - Legitimate Interests. In accordance with GDPR, all have been subjected to a Legitimate Interest Assessment (LIA) in order to balance your rights with the legitimate needs.
Third Party CDNs
On some of my services, I use third-party Content Delivery Networks in order to deliver content to users more efficiently than is/was possible using my own infrastructure.
The primary provider of CDN services I use is BunnyCDN (who's own GDPR details can be found at https://bunny.net/gdpr).
BunnyCDN's conduct is limited via a formal Data Processing Agreement, and the information on your visit they expose back to me is deliberately limited.
Relevant points are:
- Logged IP addresses are masked down to /24
- Logs are retained by the CDN for 3 days
- Access to the CDN account (and by extension, the logs within) is protected by strong authentication, including a 2nd Factor.
All requests and connections to my network services are written to access logs for the necessary purposes of Network & Information Systems Security, Billing and Account Management Purposes and Network Systems scaling and management.
The data stored which may be considered to contain Personal Data is
- Connecting IP address
- Details of the request/connection (i.e. which page and site was requested, or for non HTTP connections, which service was requested)
- HTTP Referrer string (where available)
- HTTP User-Agent header (where available)
The data collected in access logs is not passed to any third party, and will not be unless required by a lawful warrant issued by a court whose jurisdiction includes the United Kingdom (and any such warrant, even then, may be contested if it's felt to be overly broad or inappropriate - I have no more interest in allowing the Government to trample over your rights than you do).
Access logs are retained for 90 days from the date of their creation, after which they are automatically removed. However, where log lines are considered potentially relevant to a network incident, they may be retained until the investigation has completed. Those which are assessed to relate directly to the incident will be retained as part of the incident report, but will be anonymised as appropriate to the context in which they are being reported.
Any individual wishing to object to this processing should use the contact method provided within this policy. All requests will be considered upon their own merits (and the feasibility of implementation).
A limited amount of automated processing is used in order to identify "bad actor" IPs and limit their ability to cause harm to my systems. The data is not passed to any third party in order to perform this processing.
The processing of this data is not only essential to the services I provide, but is necessary to help ensure that any other data I may hold on you remains protected. Logs form an essential component of investigations into any suspected breach, and without them it may not be possible to identify (and fix) the method used to achieve a compromise. Ultimately, this limited processing benefits both you and my entire user-base.
This site does not set cookies, however your browser may have some left over from prior to my most recent migration.
As might be reasonably expected, all my systems generate backups, for the purposes of ensuring Service/Business Continuity. They may also, in extreme cases, be used during investigation of Security Incidents.
The data collected within backups is not passed to any third party, and will not be unless required by a lawful warrant issued by a court whose jurisdiction includes the United Kingdom (and any such warrant, even then, may be contested if it's felt to be overly broad or inappropriate - I have no more interest in allowing the Government to trample over your rights than you do).
Backups are generated (at least) daily and retained for 90 days from the date of their creation.
Any individual wishing to object to this processing should use the contact method provided within this policy. All requests will be considered upon their own merits (and the feasibility of implementation). However, you should be aware that it's unlikely to be possible to exclude your data from backups.
Similarly, individuals are unable to exercise their right of erasure against backups. Interfering with a backup may render it entirely unusable, undermining the legitimate purpose of the backups. However, because backups are only retained for a short period before rotating out, your data will cease to exist in a backed up form within 90 days of completion of your erasure request under different sections of this policy.
Data with backups is not accessed nor processed unless a backup restoration is required - which is (and will hopefully remain) a rare occurrence. The existence of the backups therefore doesn't change the way you're data is handled/processed other than that it means it will be stored in an additional location.
Backups are very strongly encrypted, and the necessary decryption keys are stored in an 'offline' format with strong physical security. Backups are not moved outside of the European Economic Area. Systems generating backups have the ability to upload data to the storage area, but not the ability to read it back - so even with the decryption key, compromise of a backed up host should not be sufficient to grant access to the backup contents.
The generation of backups is essential to providing and maintaining any digital service, and in some cases (such as for Tax records) may also be necessary in order to ensure compliance with a legal obligation (GDPR Section 6(1)(c)). Ensuring the continuity of service can be maintained benefits the both of us.