1. Who we are and how to contact us 2. How we collect and process personal data 3. Cookies and website visitors 4. Recipients of personal data 5. How long we store personal data for 6. How we keep personal data safe 7. International transfers 8. Your rights as a data subject 9. Updates to this policy
1. Who we are and how to contact us
We are Concilio Comms Limited (we, us or our), a limited liability company with registered number 07260886 having our registered office 84 Aldermans Hill, Palmers Green, London, N13 4PP.
You can contact us by writing to us at Concilio Comms Limited, 1 Fore Street, EC2Y 9DT or telephoning us on 020 3890 7306 or emailing email@example.com
For the purposes of applicable data protection law, we are a controller in relation to the personal data we collect and process. This means that we are responsible for deciding how and why we use personal data, and for keeping it safe. We are registered as a data controller with the Information Commissioner’s Office (ICO) with registration number ZA430553.
2. How we collect and process personal data
Clients and business contacts
We contact potential clients and other business with news and promotional material. We obtain information about these persons from a variety of sources, these include:
• our dealings with a person (e.g. if someone attends one of our events, or provides data during the course of providing services or during correspondence);
• our own research;
• word of mouth referrals from existing clients and business contacts; and
• third parties from whom we receive details of businesses who might be interested in our services.
When we do contact potential clients, we take great care to respect their privacy rights and comply with applicable marketing laws, including by doing the following:
• before making marketing calls we screen numbers against the Telephone Preference Service (TPS) and Corporate TPS lists;
• we always clearly identify ourselves and the number we are calling from;
• not emailing individual subscribers (including sole traders and general partnerships) without prior consent.
If you don’t want to hear from us you can simply unsubscribe, or you can contact us to object to direct marketing and/or to ask to have your information deleted (see ‘Your rights as a data subject’, below, for details).
The types of personal data we collect
The types of personal data we collect will vary but may include some or all of the following:
• contact information (such as name, address, telephone and email address); and
• bank details (for when we receive or make a payment).
We may process other types of personal information and, if we do, then it will be protected to the same high standard.
Why we need to use personal data
We use personal data because we need to for one or more of the following reasons:
• to perform a contractual obligation we owe to an individual;
• in order to comply with our legal obligations; or
• to pursue our legitimate interests in operating and promoting the success of our business (for example, it is in our legitimate interests to use marketing to promote our business to new clients and build business relationships), and also to perform our contractual obligations to third parties (such as paying our suppliers).
In limited circumstances, we may use personal data on the basis of your consent. If so, we will always clearly ask for your agreement to this. You are, of course, free to refuse this.
Individuals who participate in surveys and market research
We collect personal data about individuals who participate in surveys and market research. The information we collect is usually limited to your contact details (such as your name, email address and/or telephone number) and your views on topics and responses to questions we have asked. In addition, we may ask for information about your demographic (e.g. age, gender and postcode) to help us understand your responses and compare them with those of others.
This information is processed on the basis that it is in our legitimate interests (or those of our client) to carry out this research. We may contact you with follow up questions on the same basis. On occasion, third parties (such as our client) may want to contact you about your views or responses. We will only provide your contact details with your express consent.
The type of data processed in connection with surveys and market research will depend on the individual survey, though it will not usually involve the processing of special category data.
We collect, store and use personal data about individuals who apply to join us. This may include information:
• you provide to us (such as in CVs, application forms, and through correspondence);
• you provide during an interview;
• obtained from previous employers and referees; and
• provided to us by recruitment agencies.
The information we collect might include sensitive personal data, such as information about your health and sickness records. If we need to process sensitive personal data then we will ask for your explicit consent before doing so.
We only ask for references at the last stage of the application process, when making an offer of employment, and always act in accordance with the specific requirements of national laws.
How we use applicant information
We use the personal data we collect about you to:
• assess your skills, qualifications, and suitability for a role;
• carry out background and reference checks;
• communicate with you about your application; and
• keep records related to our hiring process.
We do all of this because either it is a necessary part of entering into a contract of employment with you or because we have a legitimate interest in ensuring that you are suitable for a particular role.
If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.
Retention of applicant information
We normally retain personal data about unsuccessful candidates for between 3 and 6 months from the time we inform them of our hiring decision. We retain personal data for this period so that we can demonstrate, in the event of a legal claim, we have not discriminated against an applicant and that the recruitment process was fair and transparent. After this period, we will securely destroy this applicant’s personal data. If we wish to retain personal data on file, in case future opportunities arise, we will contact the applicant and ask for his or her consent to do so.
If you are successful, the personal data you provided in the application process will be stored as part of your personnel file.
3. Cookies and website visitors
We do not normally collect personal data about visitors to our website unless they choose to provide such information when they contact us.
4. Recipients of personal data
Personal data you provide to us will be kept private and confidential, and we will not disclose or share it with other data controllers without your permission or as set out in this policy.
We will disclose data when legally required to do so. For example, to comply with an order from a court or regulator (including the Information Commissioner’s Office).
We share personal data with some of the third parties who provide services to our firm. This includes software and cloud service providers and IT support services. However, these third parties will only process personal data (which may include your information) on our behalf for specified purposes and in accordance with our strict instructions and a contract which protects the data and meets the requirements of data protection law.
In some cases we may share data with your consent, for example, if you have responded to a survey or participated in a market research project. Where we do this, we will let you know who your data will be shared with and why.
5. How long we store personal data for
We only retain personal data for as long as is necessary for the specific purpose(s) it was collected for (or for related compatible purposes such as complying with applicable legal, accounting, or record-keeping 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 its unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. How we keep personal data safe
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, damaged or destroyed, altered or disclosed. This includes both physical security measures (such as keeping paper files in secure, access-controlled premises) and electronic security technology (such as digital back-ups and sophisticated anti-virus protection).
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 instructions and they are subject to legal and contractual confidentiality obligations.
We have put in place reporting procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach when we are legally required to do so.
7. International transfers
We normally only store personal data within the UK or the European Economic Area . However, some of the technology and support services we use are provided by international organisations and/or companies which are based outside these areas.
Before using such service providers, we take steps to make sure that any personal data they process is adequately protected by:
• ensuring the recipient is in a country which the UK has deemed provides adequate protection for personal data; or
• implementing appropriate safeguards such as requiring the recipient to enter into Standard Contractual Clauses approved by the appropriate data protection supervisory authorities; or
• other measures approved under data protection laws as a means of protecting personal data.
8. Your rights as a data subject
The law provides you with certain rights in relation to your personal data. These are as follows:
• The right to access your personal data. This enables you to receive a copy of the personal data we hold about you.
• The right to request correction or completion of personal data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• The right to request erasure of your personal data. This enables you to ask us to delete or remove personal data (though this may not apply where we have a good, lawful reason to continue using the information in question). 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 (see below).
• The right to object to processing of your personal data. You can object to us processing personal data for legitimate interests purposes or for direct marketing.
• The right to restrict how your personal data is used. You can limit how we use your information (primarily to storage or for use in legal claims).
• The right to have a portable copy or transfer your personal data. We will provide you, or (where technically feasible) a third party, with a copy of your personal data in a structured, commonly used, machine-readable format. Note this only applies to automated information we process on the basis of your consent or in order to perform a contract.
• The right to withdraw consent. If we are relying on consent to process your personal data you have the right to withdraw that consent at any time.
We try to respond to all personal data 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. Please also bear in mind that there are exceptions to the rights above and some situations where they do not apply.
We may need to request additional information from you to help us confirm your identity. 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 to clarify your request.
Fees for making a request
You will not normally have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
How to make a request
If you want to exercise any of the rights described above, please email firstname.lastname@example.org or write to Data Protection Requests, Concilio Comms Limited, 1 Fore Street, EC2Y 9DT.
Your right to complain to a supervisory authority
You have the right to complain to a data protection supervisory authority (which, in the UK, is the ICO) if you are not satisfied with our response to a data protection request or if you think your personal data has been mishandled. For further information on how to make a complaint, please visit https://ico.org.uk.
9. Updates to policy
We will update this policy from time to time. The current version will always be posted on our website. This policy was last updated on 3 February 2021.