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PRIVACY POLICY

BACKGROUND:

Transaction Recruitment understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

  1. Information About Us

Transaction Recruitment.

Limited company registered in England under company number 11990687.

Registered address: The Oakley, Kidderminster Road, Droitwich, Worcestershire, WR9 9AY

VAT number: 324100170

Data Protection Officer: Danny Maddison.

Email address: gdpr@transactionrecruitment.co.uk.

Telephone number:02477360017.

Postal address: The Oakley, Kidderminster Road, Droitwich, Worcestershire, WR9 9AY

  1. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  1. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below:

  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  2. b) The right to access the personal data we hold about you. Part 10 will tell you

how to do this.

  1. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  2. d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
  3. e) The right to restrict (i.e. prevent) the processing of your personal data.
  4. f) The right to object to us using your personal data for a particular purpose or

purposes.

  1. g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  2. h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  3. i) Rights relating to automated decision-making and profiling. We do not use

your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

  1. What Personal Data Do You Collect and How?

Depending upon your use of our site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.

Data Collected How We Collect the Data

Identity Information including name, date of birth, gender

Register online, completed hard copy forms, voluntarily complete a survey or provide feedback via message boards and email, use of our website via your browser’s cookies

Contact information including address, email address and phone number.

Register online, completed hard copy forms, voluntarily complete a survey or provide feedback via message boards and email, use of our website via your browser’s cookies

Register Business information including business

online, completed hard copy forms, name, job title and profession.

voluntarily complete a survey or provide feedback via message boards and email, use of our website via your browser’s cookies

Payment information including bank account information

Register online or through appropriate forms.

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do Our Lawful Basis

Administering our business. Legitimate interests where there is a

relevant and appropriate relationship to act on your behalf.

Supplying our services to you. Legitimate interests where there is a

relevant and appropriate relationship to act on your behalf.

Managing payments for our services. Legitimate interests where there is a

relevant and appropriate relationship to act on your behalf.

Communicating with you. Legitimate interests where there is a

relevant and appropriate relationship to act on your behalf.

Supplying you with information by email and post that you have opted-in-to (you may opt- out at any time)

Legitimate interests where there is a relevant and appropriate relationship to act on your behalf.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you

the right to do so. Please contact us to find out more using the details in Part 11.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How Long We Keep It

Identity Information including name, title, date of birth and gender

Data shall be kept for no longer than is necessary for the purposes for which it is being processed.

Contact information including address, email address, telephone number

Data shall be kept for no longer than is necessary for the purposes for which it is being processed.

Business information including business name, job title, profession

Data shall be kept for no longer than is necessary for the purposes for which it is being processed.

Payment information including bank account information

Data shall be kept for no longer than is necessary for the purposes for which it is being processed.

  1. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the

attention of Danny Maddison):

Email address: gdpr@transactionrecruitment.co.uk.

Telephone number:02477 360017.

Postal Address: The Oakley, Kidderminster Road, Droitwich, Worcestershire, WR9 9AY

  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available www.transactionrecruitment.co.uk. This Privacy Notice was last updated on 24th May 2019.