01 INTRODUCTION
British Management a division of Group ADP Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us, or which we obtain, when providing services to you, when you use one of our websites www.groupadp.com and www.british.management, or when we deal with you in the course of our business. This policy applies to personal data we hold relating to clients, suppliers, employees, marketing contacts and other third parties. Depending on who you are, and how you interact with us, only some aspects of this policy may apply to you.
References to British Management and Group ADP Limited refer to the applicable entities of Group ADP, including ( but not limited to affiliates, associates of Group ADP Limited, company registration number 09344076, with the registered address at International House, 36-38 Cornhill, London EC3V 3NG
We may update the policy from time to time. You may get an update by visiting our website www.groupadp.com
02 IMPORTANT INFORMATION
Group ADP is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Privacy Manager
Group ADP Limited
International House
36-38 Cornhill
London
EC3V 3NG
Third-party links
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3. THE DATA WE COLLECT ABOUT YOU
We collect, use, store and transfer the following data:
(a) Identity and Contact Data
personal and identity data, including your names, date of birth, email address, postal address, telephone number(s), copies of passports and ID, national insurance number;
(b) Financial Data: including details transactions data of your business transactions, tax records, annual reports and accounts,
(c) Employment Data: your employment history and qualifications
(d) Profile Data: Passwords and login details for online accounts with us
(e) Technical Data: information we collect automatically when you visit our websites, including your IP address, how you use our site and the pages you visit, browser details, and device details
(f) Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
4. HOW WE COLLECT YOUR DATA
We collect your data from different sources:
(a) We collect all of the types data listed above directly from you when you interact with us;
(b) We collect some personal data from third party search providers, such as details about criminal convictions from Experian, and some Financial Data from debt management and collection agencies.
(c) We collect data from publicly available sources, and third party databases, such as newspapers, and business data repositories such as Dunn & Bradstreet.
(d) We carry out searches against government sanctions lists, and if your details are on such lists, we will receive personal information, including information about possible criminal convictions or offences.
(e) We collect Technical Data automatically when you interact with our website, by using cookies and other similar technologies.
5. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
(a) We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
(b) Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purposes
(a) To register you as a user on one of our websites
(b) To provide services to you and carry out your instructions in connection with our services.
(c) To leave a review or take a survey
(d) To enable you to partake in a competition or complete a survey
(d) To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(d) To make suggestions and recommendations to you about goods or services that may be of interest to you
(e) To invite you to networking and professional events, and to inform you about developments in our business
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. In addition, we may process your personal data without your knowledge or consent, only when this is required or permitted by law.
MARKETING
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. You will receive marketing communications from us in respect of our business and our services if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. We do not share your contact details with any third party for the purpose of that third party sending marketing. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting use using the details above at any time.
06. DATA RETENTION
We will only retain your personal data 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. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will usually keep your data for between 6 years and 10 years from inception of the last insurance policy that you incepted with us. For full details of our retention periods, please contact our data privacy manager
07. YOUR LEGAL RIGHTS
a) Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.
(b) You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
(c) Complaint to the ICO
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Other Rights
(a) 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.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
(c) 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
(d) 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(d) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(e) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(f) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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