Privacy policy — general commercial organisation — customer-facing
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Contechs Group Holdings Limited and our group companies |
Our data protection officer | Ian Brookes Group Chief Financial Officer |
Personal data | Any information relating to an identified or identifiable individual |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation |
Data subject | The individual who the personal data relates to |
Personal data we collect about you
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
your name and contact information, including email address and telephone number and company details
information to check and verify your identity, eg your date of birth
your gender, if you choose to give this to us
location data, if you choose to give this to us
your account or billing information and transaction information
your personal or professional interests
your professional online presence, eg LinkedIn profile
your contact history and saved items
information to enable us to undertake credit or other financial checks on you
information about how you use our website, IT, communication and other systems
your responses to surveys, competitions and promotions
any information contained in an uploaded document
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
from publicly accessible sources, eg Companies House;
directly from a third party, eg:
sanctions screening providers;
credit reference agencies;
from a third party with your consent;
from cookies on our website—for more information on our use of cookies, please see our cookie policy (www.contechs.com/cookie-policy)
via our IT systems, eg:
from door entry systems and reception logs;
through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
through recording and monitoring of telephone calls and other communications.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
Providing products and/or services to you | To perform our contract with you or to take steps at your request before entering into a contract |
Preventing and detecting fraud against you or us | For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us |
Conducting checks to identify our candidates or customer and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator | Depending on the circumstances: — to comply with our legal and regulatory obligations — for our legitimate interests |
To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: — to comply with our legal and regulatory obligations; — in other cases, for our legitimate interests, ie to protect our business, interests and rights |
Ensuring business policies are adhered to, eg policies covering security and internet use | For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price |
Ensuring the confidentiality of commercially sensitive information | Depending on the circumstances: — for our legitimate interests, ie to protect trade secrets and other commercially valuable information; — to comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
Preventing unauthorised access and modifications to systems | Depending on the circumstances: — for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; — to comply with our legal and regulatory obligations |
Protecting the security of systems and data used to provide the goods and services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Updating and enhancing candidate or customer records | Depending on the circumstances: — to perform our contract with you or to take steps at your request before entering into a contract; — to comply with our legal and regulatory obligations; — for our legitimate interests, eg making sure that we can keep in touch with our candidates customers about existing orders and new products or opportunities |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments | Depending on the circumstances: — to comply with our legal and regulatory obligations; — for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. | For our legitimate interests, ie to promote our business to existing and former customers |
External audits and quality checks, eg for ISO and the audit of our accounts | Depending on the circumstances: — for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; — to comply with our legal and regulatory obligations |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: — to comply with our legal and regulatory obligations; — in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in our document retention schedule (www.contechs.com/document-retention-schedule).
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. For further information as to how we treat and process special category personal data please refer to our data retention schedule (www.contechs.com/document-retention-schedule).
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at marketing@contechs.co.uk;
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
updating your marketing preferences online at www.contechs.com/dashboard/profile
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations outside Contechs Group Holdings Limited and our group companies for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
companies within the Contechs group;
third parties we use to help deliver our products and/or services to you, eg payment service providers, warehouses and delivery companies;
other third parties we use to help us run our business, eg marketing agencies or website hosts;
third parties approved by you, eg umbrella companies;
our insurers and brokers;
our banks;
Outsourced service providers, eg payroll providers.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available in our document retention schedule (www.contechs.co.uk/document-retention-schedule).
If you no longer have an account with us or we are no longer providing goods or services to you, we will delete or anonymise your account data after six years or less.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
our service providers located outside the UK; and
our customers and their services providers where strictly necessary to the performance of candidate in a role.
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Transferring your personal data out of the UK and EEA—further information
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
Access | The right to be provided with a copy of your personal data |
Rectification | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
To object | The right to object: — at any time to your personal data being processed for direct marketing (including profiling); — in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by visiting www.contechs.com/dashboard/profile or emailing gdpr@contechs.co.uk. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
complete a subject access request form — available at www.contechs.com/subject-access-request ; or
email, call or write to us—see below: ‘How to contact us’; and
provide enough information to identify yourself (eg your full name, address) and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures 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.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
the Information Commissioner in the UK
a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
For a list of EEA data protection supervisory authorities and their contact details see here.
Changes to this privacy policy
This privacy notice was published on 29/06/2023 and last updated on 06/11/2023.
We may change this privacy notice from time to time — when we do we will inform you via our website or other means of contact such as email.
How to contact us
Individuals in the UK or EEA
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details |
2 Sable Court Sylvan Way, Southfields Business Park, Basildon, Essex SS15 6SR 01268 582900 |
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).