Privacy Notice

1. The Purpose of this notice:

• 1.1

  You have legal rights with regard to the way your personal data is handled.

• 1.2

  We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights. The purpose of this notice is to provide details of how we collect and use your personal data and your right around the way that data is handled.

• 1.3

  In the course of our business activities we collect, store and process personal data about our clients, business contacts, suppliers and other third parties, and therefore in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.

• 1.4

  All people working in or with our business are obliged to comply with this policy when processing personal data.

2. ACS principles to processing personal data:

• (Processed fairly and lawfully) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
• (Processed for limited purposes and in an appropriate way) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
• (Adequate, relevant and not excessive for the purpose) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
• (Accurate) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
• (Not kept longer than necessary for the purpose) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
• (Processing in line with data subject’s rights) personal data must be processed in line with data subjects’ rights, in particular your right to:
  • 2.1.1

    request access to any data held about them by a Data Controller

  • 2.1.2

    prevent the processing of your data for direct-marketing purposes.

  • 2.1.3

    ask to have inaccurate data amended.

  • 2.1.4

    prevent processing that is likely to cause damage or distress to yourselves or anyone else.

• (Security) 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.

3. Your rights

Under certain circumstances, 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 this personal data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete your 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.
• 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. You also have the right to object where we are processing your personal data 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.
• Request the Transfer of your personal information to another party.

4. What Type of data do we collect:

The following personal data may be collected, held, and processed by the Company:

Type of data	Type and Purpose of Data
Clients	Client employee details (names, work phone number and email, job tile, work location) and related correspondence
Business contacts	Name, work phone number and email, job title, work location and correspondence
Potential employees	CV, name, contact details, interview notes, salary requirements and correspondence
Suppliers	Name, work phone number and email, job title, work location, contact details, Contracts and related correspondence

5. How will we use your personal data?

We will only use your personal information when the law allows us to do so.  Most commonly, we will use your personal information in the following circumstances:

• To perform a contract we have entered into with you;
• To comply with a legal obligation; and
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests); or.
• Where it is needed in the public interest or for official purposes.

We may also use aggregate information and statistics in order to help us to develop our website and our services. These statistics will be anonymous and will not include information that can be used to identify you.

6. Retention of your personal data.

We will only retain your personal information 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. Our specific data retention periods are set out below

Data Category	Type and Purpose of Data	Retention period
Clients	Contracts of engagement, project details. Accounting and payment details and related correspondence	7 years after end of relationship
Business contacts	Name, work phone number and email, job tile, work location and correspondence	3 years after end of relationship
Potential employees	CV, name, contact details, interview notes, salary requirements and correspondence	1 year post campaign
Suppliers	Contact details, Contracts and related correspondence	7 years post completion / termination