Privacy Policy2019-02-27T10:46:02+00:00
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Amber Associates Recruitment Ltd Privacy Policy & Cookie Notice-Oct 17th 2018

Amber Associates Recruitment Solutions respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

Even though the UK has expressed its intention to leave the EU, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and the newly introduced Data Protection Bill has become the Data Protection Act 2018.

Your new rights under the GDPR are set out in this notice.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is Amber Associates Recruitment Solutions Ltd “Amber Associates”of 20-22 Wenlock Road, London. N1 7GU Amber Associates Recruitment Solutions Ltd is a UK registered company dedicated to recruitment of permanent, temporary and contract workers. Our company number is 11705562.

Our nominated Data Protection contact is Mark James, Chief Information Officer and is reachable on mark@amber-associates.co.uk

Please also use the Glossary at the end of this policy to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Amber Associates Recruitment Solutions Ltd , collects and processes your personal data through your use of this website, including any data you may provide through this website when you contact us, process a timesheet, sign up to our newsletter or utilise our recruitment services and make contact with us in any way. This includes clients, candidates and suppliers.

This website is not intended for children and we do not knowingly collect data relating to children. If you are under 13 years of age please leave Our site.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

WHO WE ARE AND WHAT WE DO

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business).  We collect the personal data of the following types of people to allow us to undertake our business;

  • Prospective and placed candidates for permanent, temporary or contract roles
  • Prospective and live client contacts
  • Supplier contacts to support our services
  • Employees, consultants, professional advisors.

We collect information about you to carry out our core business and ancillary activities for both clients, candidates and suppliers.

CONTROLLER

This privacy notice is issued on behalf of the Amber Associates so when we mention  “we”, “us” or “our” or “Amber Associates”in this privacy notice, we are referring to Amber Associates Recruitment Solutions Ltd who is responsible for processing your data. Amber Associates Solutions Limited is the Data Controller and is also responsible for this website. Registered number with the ICO : ZA480530

We have appointed a Chief Information Officer 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 Protection contact using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Amber Associates Recruitment Solutions Limited

Name and title of primary Data Protection contact: Mark James, CIO & Managing Director

Email address: mark@amber-associates.co.uk

Postal address: 20-22 Wenlock Road, London. N1 7GU

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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version of our Privacy Policy was last updated 17thOctober 2018

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website 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.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, marital status and dependants, next of kin and emergency contact information, National Insurance number, copy of driving licence, copies of right to work documentation, references, security ratings and other information included in a CV or cover letter or as part of the application process, job titles, work history, working hours, training records and professional membership, compensation history, performance information about your use of our information and communications systems and photographs.
  • Contact Data includes billing address, delivery address, email address, location of employment or workplace, telephone numbers compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
  • Financial Dataincludes bank account details, payroll records, tax status information, remuneration, annual leave, pension and benefits information.
  • Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us, and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

INFORMATION ABOUT CRIMINAL CONVICTIONS

We may only use information relating to criminal convictions where the law allows us to do so and our client specifically request, it. This will usually be where such processing is necessary to carry out our legal or contractual obligations.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we may hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with recruitment services). In this case, we may have to cancel the services you have engaged us for but we will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • submit your CV;
    • apply for / request our recruitment services;
    • request marketing to be sent to you; such as the data science recruitment reports
    • give us some feedback.
    • Provide us with services
  • Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Our cookie policy is available upon request.
  • Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out:
    • Identity and Contact Data from sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card and personal recommendations.
    • Technical Data from third parties including, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors.
  • Identity and Contact Data from publicly availably sources such as Companies House and Linked In and any such equivalent register based inside the EU.
  1. HOW WE USE YOUR PERSONAL DATA

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

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other services we offer that are similar to those that you have already been provided with or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement.  However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

We have set out below, in a table format, 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.

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 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 in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client / candidate (a) Identity

(b) Contact

(c) Marketing and Communications

Performance of a contract with you
To process and deliver your assignment or service including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or provide feedback

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, continue to supply relevant services and improve how customers use our products/services)

Provide recruitment services to you which will include:

a.      Making a decision about your recruitment.

b.     Determining the terms on which you work for us.

c.      Checking you are legally entitled to work in the UK.

d.     Administering the contract we have entered into with you.

e.      Business management and planning, including accounting and auditing.

f.       Conducting performance reviews, managing performance and determining performance requirements.

g.     Making decisions about your continued engagement.

h.     Making arrangements for the termination of our working relationship.

i.      Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

j.      Ascertaining your fitness to work.

k.     Managing sickness absence.

l.      Complying with health and safety obligations.

m.    To prevent fraud.

n.     To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

o.     Equal opportunities monitoring.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Usage

a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated, continue to supply relevant services and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about roles, candidates or candidates services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can manage your data use by contacting us at any time.

We may use your Identity, Contact, Technical and Usage 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 may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have sent us your CV, requested information or services from us, engaged services from us or if you provided us with your details when you entered a competition or registered for a promotion or annual reports and, in each case, you have not opted out of receiving that marketing, which you can do ant any time.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Amber Associates for marketing purposes.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a contract, services engaged, warranty registration, service experience or other transactions.

OUR USE OF COOKIES

Cookies are small text files that are placed on your computer’s web browser by Websites that you visit; they are widely used in order to make Websites work or work more efficiently.

Commonly, they will either be Functionality Cookies, or Tracker Cookies.

Our Site www.tamber-associates.co.ukdoes not place Cookies on your computer or device to provide functionality.

When using Our Site, you may also receive certain Tracker Cookies on your computer or device. Tracker Cookies are those placed by Websites, services, and/or parties other than us. Tracker Cookies are used on Our Site for basic usage tracking and visitor statistics only.

Tracker Cookies are not integral to the functioning of Our Site and your use and experience of our site will not be impaired by refusing consent to Tracker Cookies.

All Cookies used by and on our site are used in accordance with current Cookie Law as it has been implemented in various jurisdictions.

Before any Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; this will not affect the functioning of our site. You will be given the opportunity to allow or block Tracker Cookies.

The following Tracker Cookies may be placed on your computer or device:

Name of Cookie Provider Purpose Retained

for

Google Analytics Google Inc. Basic Usage tracking and  Anonymized Statistics 26 Months

You can choose to enable or disable Tracker Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only Tracker Cookies. By default, most internet browsers accept Tracker Cookies, but this can be changed.

You can set your browser to refuse all or some Cookies, or to alert you when websites set or access Cookies. If you disable or refuse Tracker Cookies, please note that the functionality of our website will not be affected.

However, depending on the level of cookie blocking you employ this may affect other websites you visit where similar cookies are Functionality Cookies on that website.

For further details, please consult the help menu in your internet browser or the documentation that came with your device or for more information about how to disable cookies in your browser please visit http://www.aboutcookies.org.uk/managing-cookies

To opt out of being tracked by Google Analytics across all Websites visit https://tools.google.com/dlpage/gaoptout

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

CHANGE OF PURPOSE

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please get in touch.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Where we store and process your personal data

STORAGE

All information you provide to us is stored on our secure servers. 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.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties such as suppliers and service providers
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written, contractual instructions.

  1. INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our written, contractual instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

Where we have attained your consent to store and process your data, we will only do so for a period of six calendar years from the relevant date of your consent. This is a period of retention we have assessed as necessary and reasonable for the proper fulfilment of the purposes the data was collected 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.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by Contacting us.

By law we have to keep basic information about our customers, clients and candidates (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Data Subject Access Request below for further information. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have Data Subject Access rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us. If you wish to underatdn them in more detail please refer to the ICO website. (www.ico.org.uk)

NO FEE REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts.  The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process. In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.  To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

  • clients for the purpose of introducing candidates to them
  • candidates for the purpose of arranging interviews and engagements
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you
  • subcontractors including email marketing specialists and event organisers
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • Referencing agencies, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
  • service providers acting as processors based in the EU and USA who provide IT and system administration services.
  • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS IN DETAIL

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 the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

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.

For more information on your Rights and how to ensure them please contact the ICO. www.ico.uk.org.