This policy describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and other national implementing laws, regulations and secondary legislation.
For the purpose of the Data Protection Legislation and this notice we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
How we may collect your personal data
We obtain personal data about you, for example, when:
- When you contact us in respect of the services we provide
- You engage us to provide our services and during the provision of those services
- You contact us by email, telephone, post, website or social media (for example when you have a query about our services) or
- From third parties and/or publicly available resources (for example: work supply chains, e.g. Local Heroes, Check a Trade or credit reference agencies)
The kind of information we hold about you
The information we hold about you may include the following:
- your personal details (such as your name and/or address)
- contact details such as email addresses and telephone numbers
- bank details or card details
- copy of identification, such as passport or driving licence
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services
- details of any services you have received from us
- our correspondence and communications with you
- information about any complaints and enquiries you make to us
- information from research, surveys, and marketing activities
- Information we receive from other sources, such as publicly available information, and information provided by our clients.
How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with our clients and to comply with our legal obligations.
This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client. We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes. We may process your personal data for certain additional purposes with your consent and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
We may also use your personal information in the following situations, which are likely to be rare: (1) where we need to protect your interests (or someone else’s interests), (2) where it is needed in the public interest or for an official purpose. Please note that we may process your personal data for more than one lawful
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered between our clients and us (which will most usually be for the provision of our services)
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be an employee, subcontractor, supplier or customer of our client
- provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- fulfil our legal and regulatory obligations
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you. If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so. Data retention We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided
- any statutory or legal obligations
- the purposes for which we originally collected the personal data
- the lawful grounds on which we based our processing
- the types of personal data we have collected
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Why might you share my personal data with third parties? We will share your personal data with third parties where we are required by law, where it is required by our regulator, necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, professional advisory services and administration services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may need to share your personal data with a regulator or to otherwise comply with the law.
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- 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 exercised your right to object to processing (see below).
- 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 situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent.
If you want to exercise any of the above rights, please email us at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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