When do we collect personal information and what personal information do we collect?
We may collect personal data about you as follows:
We do not collect personal data that relates to individual consumers nor do we collect any special category data (save in respect of our staff members and candidates for employment, which is explained in the specific applicable privacy notices).
We collect visitor information by using cookies and when you use the sharing icons (provided by Share This) to share content from our website or access other websites which collect statistical data about our users’ browsing actions and patterns but does not identify any individual.
We use information about you as follows:
If you instruct us to provide services (to you or the organisation you work for), we will use the information you provide to supply our services, to carry out our contractual obligations and to fulfil any legal obligations arising from your instructions. This may include:
We may also use your personal data to enable us to review, develop and improve our website and services on the basis that we have a legitimate interest to do so. We may also notify you about changes to our website, services or our organisation on the basis that this is compatible with our original use of your information
We expect and require that our customers comply with the provisions of the General Data Protection Regulation and any other legislation governing the processing of personal data and have an appropriate lawful reason for the processing of any personal information that is supplied to us in the course of us providing services to them (including any third party personal data supplied).
Some of the information you provide to us will be transmitted electronically, e.g. information provided via our website or by email. We would remind you that information transmitted via the internet is not completely secure and although we will do our best to protect any information transmitted in this way, we cannot guarantee its complete security.
We use a combination of secure EU based cloud servers and cloud services supplied by Microsoft to store and process any data that we may have about you. Limited amounts of data may also be held on individual PCs and laptops. No personal data you provide to us is transferred to, or stored at, a destination outside the European Economic Area.
We have put in place appropriate security measures to prevent your personal data being accidently lost, accessed or used in an unauthorised way, altered or disclosed. Access to our cloud servers and cloud services are controlled via user authentication, we utilise Windows and application password control and Microsoft EMS to control security on mobile devices.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may disclose your personal information to third parties if we are under a duty to disclose or share it in order to comply with any legal obligation (for example our auditors, our insurers, professional advisers and HMRC), as a necessary part of providing services to you or as part of our contractual obligations, or with your consent. However, we will only ever share information about you that is necessary in line with the above objectives and if we have put in place suitable safeguards to ensure your personal data is secure and only used for the purposes stated above.
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
Personal data for our customers is held for as long as we retain a relationship with them and then for 7 years from the end of such relationship, unless there is a legal reason to retain the information longer.
Personal data collected by means of recording inbound and outbound phone calls is deleted 2 weeks after the date of the relevant recording.
Personal data for prospective customers and/or those who have contacted us to enquire about our services shall be reviewed annually to update any inaccurate information. Any prospective data that does not need to be retained shall be marked to ensure that it is not utilised in future and shall, once our CRM systems have been updated, be deleted.
Personal data relating to individual contacts with our supplier and technology supplier organisations shall be retained for as long as we retain a relationship with those organisations and then for 7 years from the end of such relationship, unless there is a legal reason to retain the information longer.
Personal data relating to job candidate and our staff shall be held in accordance with the retention schedules set out in the relevant job candidate and staff privacy notices.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy (b) where our use of the data is unlawful but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Watermans Business Park
Surrey TW18 3BA
You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.