ABC Privacy Notice
ABC Programme Consultants Limited (ABC) is committed to building your confidence and trust by complying with data protection legislation and best practices that protect your privacy and safeguards your personal information.
This Privacy Notice explains how we collect, use, store, share and protect your personal information. We are registered with the UK Information Commissioner's Office. Our data protection registration number is ZA568161.
We promise at ABC that your personal data shall be:
- processed lawfully, fairly and in a transparent manner.
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’).
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’).
- accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’).
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed(‘storage limitation’).
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
How does ABC collect your personal data?
We collect personal information in the course of our business.
We collect directly from you when you:
- You email us or call us to enquire about our products and services or submit an online form getting in touch or asking for our online materials
- We have been asked to contact you in relation to our business activity (i.e. your manager has asked us to speak to you about a service we provide or someone in your network has made an introduction)
- You apply for a job with us (See ABC Recruitment Privacy Notice in Annex A of this document.)
- You use our website (i.e. IP address in Google analytics)
- We become business associates/connections
From other sources:
- Partnerships with trusted third parties and stake holders.
- Individuals and organisations whom you have confirmed consent with.
- Publicly available information.
- Government, tax or law enforcement agencies.
What personal data does ABC collect?
The information we collect will change based on the reason we are processing your data. We will never collect more from you than we need. Typically, this will include personal identifiers such as your name, date of birth, title and contact details including postal address, post-code, email telephone number and organisations name.
Occasionally, as part of the functions described in this policy, we may need to process special category of data. We endeavour to do so only when necessary and we will treat and process such data with great care and in accordance with the applicable data protection laws.
Enquiring about our products and services or asking for our materials online
When you contact us enquiring about our products and services, we will collect whatever information is necessary prior to taking steps to enter into a contract with you.
This information will typically include the name and place of work of key contacts in your organisation and their contact details. We will also process any information you submit via our online forms.
We may also process any other information that we have legitimately collected about you in relation to our other services where this other purpose was known to you at the point of data collection. This information would only be processed in relation to engaging in a contract at your request.
Contacting you after a referral
When we contact you at the request of someone else, we will always tell you who we are and where we got your information from.
We will do this as soon as is reasonably possible and no later than 28 days after first receiving your contact details. Wherever possible, we will ask the person referring you to us to make the introduction or to check with you whether it is ok for us to call you first.
The information that we will have processed prior to that point will be likely minimal and will include your name, job title/ place of work and a contact point such as an email or telephone number.
The lawful basis we rely on when contacting you about our products or services at the request of someone else will be different depending on the context.
For the most part, it will be in our legitimate interest to do so and you can request that we stop processing your data.
Where you have agreed for us to get in touch, we will be doing so based on your consent and you can withdraw this at any time.
You apply for a job with us
If we advertise a job posting or you are interested in working as a contractor/consultant for us, we may process some of your personal data so as to take steps to enter into a contract with you.
Typically, we will process your name, contact information and your CV and cover letter. Depending on the route you came into us, we may also look at your publicly available profiles in advance of an interview, such as a LinkedIn page or a professional Twitter account. We will also contact those you offered as a reference for you.
If you let us know about a disability or health condition (or provide us with any other special category data), we will process this data under our legal obligations in relation to employment and equality laws.
If you are successful in your application and we want to offer you a job, we will process more information than this. (See ABC Recruitment Privacy Notice in Annex A of this document.)
You use our website
Like many other websites, the ABC website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and most do not identify you as an individual.
However, some cookies and tagging/ tracking technologies that we use, such as Google Analytics, do let us know some information which may constitute personal data. An example of this is our Google Analytics Cookies that tell us about which of our pages a certain IP address accessed, when and where it was accessed from.
We become business associates/connections
If you are a business connection, for example, we meet you at a networking event, we will only collect the information you choose to provide to us which typically includes your name, company address, company telephone number and company email address. Our legal basis for processing your information is legitimate interests and we will retain it for 12 months following our last meaningful contact.
We contact you for marketing purposes
Where we have publicly found your contact details (e.g. info@example-company.com), we may send you business marketing information by email where we think you may be interested in our products or services.
Where we have a corporate email address for you which contains identifiable information (e.g Joe.bloggs@example-company.com) we may send you business marketing information by email, if we think your products or services may be of interest to you.
We may also telephone you to discuss our products and services providing your telephone number is not listed on the Corporate Telephone Preference Service list (CTPS).
You have the right to object, and if you do we will respect your wishes and remove you from our mailing list, if this is the case please email victoria.angel@abcprogrammes.co.uk.
In summary the lawful basis under which we process your personal data are:
- legitimate interests
- processing under contract
- processing using your consent
How do we use your personal information now that we have collected it?
We use personal information about you in connection with the following purposes:
Fulfilling your requests:
- Provide you with the information, products and services that you have requested from us.
- Complete any transaction you are undertaking with us.
- Carry out our obligations arising from any contracts entered between you and us.
- Allow you to participate in interactive features of our service, when you choose to do so.
- Process a job application or enquiry.
- Meet a legal or statutory obligation.
Marketing:
- Provide you with information, suggestions and recommendations about other services we offer that are similar to those that you have already purchased or enquired about (unless you have opted out).
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you, which may be based on your activity on our website(s) or the website of another third parties’ websites (the information we use for this purpose is collected using cookies and you can adjust your cookie settings using the tab displayed on the home page); and,
- Before getting in touch by telephone, we will always check against the Telephone Preference Service (TPS) and/or the Corporate Telephone Preference Service (CTPS), whichever is appropriate.
If you no longer wish to be contacted for marketing purposes, please email: victoria.angel@abcprogrammes.co.uk or click on the unsubscribe button at the bottom of the emails we send.
Service Improvements and account management:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To notify you about changes to our service.
- To manage and operate your account with us.
We do not use profiling or automated decision-making tools.
How long do we hold your personal information?
We will hold your data for no longer than we need it for. This will be context dependant on our relationship with you and why we are processing your data. We may have legal (i.e. financial obligation) reasons to keep your data beyond its immediate use, but this will never be for longer than industry standard.
Where not already stated in this policy, you can view our retention schedule by contacting victoria.angel@abcprogrammes.co.uk
Sharing your personal information
If we have a business relationship with you, we may pass some information to our third-party service providers, agents, subcontractor and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
When we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we will always have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have consented to this.
These third parties’ services providers may include:
· First for Contractors Subcontractor Management Application
· Giant Group/Giant Screening
· DocuSign
· XERO accounting software
· manatal.com
We may share your information with credit reference agencies and other companies for use in credit decisions and for fraud prevention.
We may share your information with third party contractors or organisations working with ABC to fulfil supplier contracts.
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our staff and customers.
However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
If you use our services while you are outside the UK/EEA, your information may be transferred outside the EEA in order to provide you with those services.
Keeping your personal information safe
We will never keep paper copies of any of your personal data.
We use the MS Teams platform to store information as it provides some of the best cyber security in the business. To read the detailed specification of how they keep your data safe, please click on the link below.
We use manatal.com to manage potential customers and current customers information. This system has servers in the USA and your data will be hosted in this country. For further information about this platform, please contact us.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet and this can never be guaranteed to be 100% secure.
As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
Once we receive your information, we make our best effort to ensure its security on our systems.
Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Keeping children safe
We are concerned to protect the privacy of children aged under 18. If you are aged under 18‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible, unless we have a legal obligation to process it, for example as part of our role as DPO.
Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at: victoria.angel@abcprogrammes.co.uk.
Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
What are your data protection rights?
You have the following rights in relation to your personal data:
- Access: The right to request access to and a copy of your personal information
- Restriction: You can ask us to pause processing your information in certain circumstances (e.g. you are disputing its accuracy).
- Rectification: You can have any inaccuracies in your personal information corrected.
- Deletion: You can ask us to delete all your personal information in certain circumstances (e.g. if the information is no longer necessary for the purposes for which it was collected).
- Objection: You can object to us processing your personal information in certain circumstances.
- Objection to marketing: Please see section 7 (Marketing and advertising) below, for information about how to opt-out of direct marketing communications.
- Portability: You can ask us to transfer your information electronically to you or another organisation in certain circumstances.
- Withdrawal of consent: Where we rely on your consent to process your information, you can withdraw consent at any time, although this will not affect our uses of your personal information prior to the withdrawal of your consent; and
To lodge a complaint with the Information Commissioner’s Office (“ICO”) or other relevant supervisory authority: You can complain to the ICO (ico.org.uk/global/contact-us/email) or other relevant supervisory authority about any aspect of our handling of your information.
More information about the right to complain can be found at https://ico.org.uk/for-the-public. If you have any questions about these rights, or you would like to exercise them, please contact us by emailing victoria.angel@abcprogrammes.co.uk
Please be aware that you are under no obligation to provide us with your personal information. However, failure to do so may, in some circumstances, prevent us from being able to provide you with products and services, or otherwise interact with you.
When exercising your data protection rights we may ask you to verify your identity in order to help us respond efficiently to your request.
If you would like to exercise any of the above rights, please email or write to us at victoria.angel@abcprogrammes.co.uk
All of these rights are free to exercise and we will do our best to respond to you as quickly as possible and in any event, within one month of receipt of your written request.
We will inform you within one month of receipt of such request if we will need longer to respond, for example due to the complexity of the request.
We want to make sure that your personal information is accurate and up to date. Please always let us know if you think that it is not and needs updating. Contact victoria.angel@abcprogrammes.co.uk
This policy was updated on the 5th August 2020.
ABC Recruitment Privacy Notice
ABC Programme Consultants Limited, Larch Rising, Quarry Road, Oxted, Surrey, RH8 9HE, United Kingdom, Company number 09376555, (“We”, “Us”) are committed to protecting and respecting your privacy.
This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.
We use First for Contractors Subcontractor Management Application, Giant Group/Giant Screening and DocuSign all are online software applications to assist with Our recruitment process.
We use First for Contractors Subcontractor Management Application, Giant Group/Giant Screening and DocuSign to process personal information as data processors on Our behalf.
First for Contractors Subcontractor Management Application, Giant Group/Giant Screening and DocuSign is only entitled to process your personal data in accordance with Our instructions.
Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice which has been provided to you separately or is available on Our Website.
Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.
Information We collect from You
We collect and process some or all of the following types of information from you:
- Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
- In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.
- If you contact Us, We may keep a record of that correspondence.
- A record of your progress through any hiring process that we may conduct.
- Details of your visits to First for Contractors Subcontractor Management Application, Giant Group/Giant Screening, manatal.com and DocuSign Websites including, but not limited to, traffic data, location data, weblogs and other communication data.
Information We Collect From Other Sources
First for Contractors Subcontractor Management Application, Giant Group/Giant Screening provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
First for Contractors Subcontractor Management Application, Giant Group/Giant Screening technologies allows Us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Our processing of your personal data for the purposes mentioned above is based:
- in part, on our legitimate interest in evaluating your application to manage our relationship with you and to ensure that we recruit the appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally.
- in part, on our need to perform contractual and precontractual measures in respect of our relationship with you:
- in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
- In part, on your consent, when we ask you if you wish to be part of our optional recruiting programs.
We use information held about you in the following ways:
- To consider your application in respect of a role for which you have applied.
- To consider your application in respect of other roles.
- To communicate with you in respect of the recruitment process.
- To enhance any information that we receive from you with information obtained from third party data providers.
- To find appropriate candidates to fill Our job openings.
Automated decision making/profiling
We may use technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.
Disclosure of Your Information
As set out above, we pass your information to our third party service providers, including First for Contractors Subcontractor Management Application, Giant Group/Giant Screening and DocuSign, who use it only in accordance with our instructions and as otherwise required by law.
Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.
How we store your Personal Data
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
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 through any online means, therefore any transmission remains at your own risk.
Where We store your Personal Data
Where we store your personal data in our own systems, it is stored on our secure servers within the UK.
If you would like further information please contact Us (see ‘Contact’ below).
How long we keep your Personal Data
Your personal information will be deleted on one of the following occurrences:
- deletion of your personal information by you (or by another person engaged by you); or
- receipt of a written request by you (or another person engaged by you) to us.
- If you are unsuccessful in your application six months after the last communication
- If you are employed by us six years after contract termination.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- contact us using our Contact details below
- let Us have enough information to identify you,
- let Us have proof of your identity and address, and
- let Us know the information to which your request relates.
We hope that We can resolve any query or concern you raise about Our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Contact
All questions, comments and requests regarding this Privacy Notice should be addressed to victoria.angel@abcprogrammes.co.uk