Contact details
What information we collect, use, and why
To provide and improve products and services for clients
- Names and contact details
- Addresses
- Gender
- Occupation
- Date of birth
- Transaction data (including details about payments to and from you and details of products and services you have purchased)
- Usage data (including information about how you interact with and use our website, products and services)
- Information relating to compliments or complaints
- Video recordings
- Audio recordings (eg calls)
- Records of meetings and decisions
- Account access information
- Website user information
For the operation of client or customer accounts
- Purchase or service history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
- Technical data, including information about browser and operating systems
For information updates or marketing purposes
- Profile information
- Purchase or account history
- Website and app user journey information
- IP addresses
For research or archiving purposes
- Purchase or client account history
To comply with legal requirements
- Name
- Contact information
- Client account information
- Any other personal information required to comply with legal obligations
For recruitment purposes
- Contact details (eg name, address, telephone number or personal email address)
- National Insurance number
- Copies of passports or other photo ID
- Employment history (eg job application, employment references or secondary employment)
- Education history (eg qualifications)
- Right to work information
- Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Security clearance details (eg basic checks and higher security clearance)
We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Trade union membership
For dealing with queries, complaints or claims
- Payment details
- Account information
- Call recordings
- Photographs
- Relevant information from previous investigations
- Customer or client accounts and records
- Financial transaction information
- Information relating to health and safety (including incident investigation details and reports and accident book records)
- Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights, which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access
You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more.
Your right to rectification
You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more.
Your right to erasure
You have the right to ask us to delete your personal information. Read more.
Your right to restriction of processing
You have the right to ask us to limit how we can use your personal information. Read more.
Your right to object to processing
You have the right to object to the processing of your personal data. Read more.
Your right to data portability
You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more.
Your right to withdraw consent
When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Consent
We have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract
We have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation
We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests
We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We can only offer and advise on relevant products and services with data collected.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
For the operation of client or customer accounts, we rely on the legitimate interest that we can only review and advise on relevant products and services with data collected.
For information updates or marketing purposes, we rely on the legitimate interest that we can only offer relevant products and services with data collected.
For dealing with queries, complaints or claims, we may rely on legal obligation. We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Where we get personal information from
- Directly from you
- Publicly available sources
- Providers of marketing lists and other personal information
- Suppliers and service providers
- Third parties, including other business contacts and acquaintances, such as at a referral network
How long we keep information
We store personal information for as long as they are a client and then up to 2 years thereafter. Where personal information is held for marketing purposes, this will be held until such time that an individual requests removal.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
Information Commissioner’s OfficeWycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: ico.org.uk/make-a-complaint
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