The majority of the information we hold and process relates to company data and we have a legitimate business reason to do this. However some of our clients operate their business from a home address and use personal email addresses or telephone numbers, therefore the following privacy policy relates to the information we hold and process which is classed as “personal data”.
1. Introduction
1.1“Personal data” is any information about a living individual which allows them to be identified from that data (for example a name, photographs, videos, email address, or address). Identification can be by the information alone or in conjunction with any other information. The processing of personal data is governed by the Data Protection Act 2018, the General Data Protection Regulation 2016/679 (the “GDPR” and other legislation relating to personal data and rights such as the Human Rights Act 1998). 1.2 Whilst we and the other data controllers will take every effort to ensure your privacy, it may be possible to identify you from the information you provide to us or other third party information. The purpose of this notice is to inform you about how we will deal with your personal data in the event that you can be directly or indirectly identified. Where you share with us personal data about a third party, you should first obtain their consent unless it is not possible to do so. 1.3 We also share personal data with our suppliers. 1.4 The organisations referred to above are joint data controllers. This means we are all responsible to you for how we process your data 1.5 Each of the data controllers have their own tasks and a description of what data is processed and for what purpose is set out in this Privacy Notice. In the rest of this Privacy Notice, we use the word “we” to refer to each data controller, as appropriate. 1.6 What data do the data controllers listed above process? They will process some or all of the following where necessary to perform their tasks:
- Names, titles, and aliases, photographs;
- Contact details such as telephone numbers, addresses, and email addresses;
- Where relevant, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications.
1.7 If you contact us, we may keep a record of that correspondence. 1.8 We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. 1.9 Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, as explained in our Cookies policy. 1.10 Details of personal information you provide to us either in paper or any other form, for the fulfilment of a mutual contract between us. 1.11 This policy should be read in conjunction with our cookie policy.
2. Uses Made Of The Information
2.1 We use information held about you for our legitimate business interests and where relevant any contractual obligations we have with you. We use your Data to: 2.1.1 Ensure that content from our site is presented in the most effective manner for you and your device. 2.1.2 Provide you with information, products or services that you request from us or which we feel may be of interest you, where you have consented to be contacted for such purposes. 2.1.3 Carry out our obligations arising from any contracts entered into between you and us. 2.1.4 Allow you to participate in interactive features of our service, when you choose to do so. 2.1.5 Notify you about changes to our service. 2.2 We may use your Data to comply with any legal obligations. We may also use your Data to send you information about goods and services which may be of interest to you. We may contact you about these by telephone. 2.3 If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data. 2.4 We will store your personal Data only for as long as necessary for the purposes of providing access to our Site and related services to you; as required by law.
3. What is the legal basis for processing your personal data?
3.1 Most of our data is processed because it is necessary for our legitimate interests, or the legitimate interests of a third party (such as another data controller). We will always take into account your interests, rights and freedoms. 3.2 Some of our processing is necessary for compliance with a legal obligation. Where your information is used other than in accordance with one of these legal bases, we will inform you.
4. Sharing your personal data
4.1 Unless otherwise agreed your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- Our agents and contractors. For example, we may ask a supplier to provide us with services
- Our members; and
- Government agencies, departments and other third party organisations
5. Security of your personal data
5.1 We are committed to protecting the security of your Data. We use a variety of security technologies and procedures in order to do this. As effective as modern security practices are, no physical or electronic security system is entirely secure. We will continue to update policies and implement additional security features as new technologies become available. 5.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6. Links to other sites
6.1 Parts of our Site contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. We suggest that you carefully review the privacy policies of each site you visit before you submit any Data to those websites
7. How long do we keep your personal data?
7.1 We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 8 years. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
8. Your rights and your personal data
8.1 You have the following rights with respect to your personal data: 8.2 When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights. 8.3 The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within one month.
- There are no fees or charges for the first request but additional requests for the same data may be subject to an administrative fee.
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data You have the right to request that we stop processing your data. Upon receiving the request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
9. Transfer of data abroad
9.1 Any electronic personal data transferred to countries or territories outside the EU will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union. 9.2 Our website is also accessible from overseas so on occasion some personal data (for example in a newsletter) may be accessed from overseas.
10. Further processing
10.1 If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
11. Changes To Our Privacy Policy
11.1 Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.
12. Contact details
12.1 Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at: info@asups.co.uk
13. How to make a complaint
13.1 If you are unhappy with the way in which your personal data has been processed you may in the first instance contact us using the contact details: call +44 (0) 2393 200 180 or email info@asups.co.uk