We are committed to ensuring that your privacy is protected and your personal data is handled in a safe and responsible way.
It is provided to aid you in understanding what we do with any personal data that is obtained from you. We endeavour to protect your privacy and any information we hold on you will be used only
(i) for the purposes we originally collect it for (as explained in this Policy), and
(ii) for other purposes which are compatible with those original purposes. We will update this Notice from time to time to explain how we use your personal data, including any new “compatible” purposes we decide to use your data for.
- The Data Protection Act 1998
- The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
- Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”)
- General Data Protection Regulation (GDPR) (EU) 2016/679
We can collect personal information to allow us to provide you with information on our activities and services that we believe will be of benefit. Under the data protection law this is referred to as ‘Legitimate Interests’.
Legitimate Interests means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests. When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will 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).
WHO WE ARE
We Are All Connected Ltd (known hereafter as ‘We Are All Connected’) is a digital marketing agency and company registered in England and Wales (number 07553091).
Our registered and postal address is Suites 4&5, Fifth Floor, Vantage Point, New England Road, Brighton BN1 4GW United Kingdom
Our main office telephone number is +44 1273 921866 and the email address of general enquiries is email@example.com
HOW DO WE GET INFORMATION?
Most of the data we handle is commercial (i.e. business-to-business or ‘B2B’) data, but from time to time we also handle personal information. The personal information we process is provided to us directly by you for one of the following reasons:
- You have submitted an enquiry to us.
- You wish to attend, or have attended, an event of ours.
- You have applied for a job, internship or placement with us.
We also receive personal information indirectly, in the following scenarios:
- An employee of ours gives your contact details as an emergency contact or a referee.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.
Your right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right at https://ico.org.uk/your-data-matters/your-right-of-access/
Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right at https://ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected/
Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right at https://ico.org.uk/your-data-matters/your-right-to-get-your-data-deleted/
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right at https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data/
Your right to object to processing
You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests. You can read more about this right at https://ico.org.uk/your-data-matters/the-right-to-object-to-the-use-of-your-data/
Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. https://ico.org.uk/your-data-matters/your-right-to-data-portability/
You are not required to pay any charge for exercising your rights. We have one month to respond to you.
SHARING YOUR INFORMATION
We will not share your information with any third parties for the purposes of direct marketing.
We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
In some circumstances we are legally obliged to share information. For example under a court order or at the request of a regulatory body such as the ICO. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information.
LINKS TO OTHER WEBSITES
Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.
We will hold your personal information on our systems for only as long as is necessary for the relevant activity, e.g. we will keep a record of donations for as long as financial regulations require. If you request us not to send you marketing information we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
YOUR RIGHT TO COMPLAIN
We intend to comply to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us at firstname.lastname@example.org and we will respond.
If you remain dissatisfied, you also have the right to make a complaint to the Information Commissioner’s Office,or to seek a remedy through the courts if you believe that your rights have been breached.
We do not provide services directly to children or proactively collect their personal information. However, we are sometimes given information about children when approached by schools and colleges regarding opportunities for work experience and internships. The information in the relevant parts of this notice applies to children as well as adults.
The language contained within this privacy notice is intended to be of a standard of clarity acceptable to the Plain Language Commission. A person with a reading age of at least 14 should be able to follow its main points.
HOW YOU CAN CONTACT US
We use a third party Voice over Internet Protocol (‘VOIP’) telephone service. VOIP is a methodology and group of technologies for the delivery of voice communications and multimedia sessions over Internet Protocol networks, such as the Internet.
When you call our office telephone number, our third party collects Calling Line Identification (CLI) information on our behalf. This is the phone number you are calling from (if it’s not withheld). We hold a log of the phone number, date, time and duration of the call, but do not audio-record the call itself.
We use this information to understand the demand for our services and to improve how we operate. We may also use the number to call you back if you have asked us to do so, if your call drops, or if there is a problem with the line. We may also use it to check how many calls we have received from it.
We do not routinely audio record any calls, but we might make notes. If we want to audio record a specific call with you, we will ask your permission in advance.
We also hold statistical information about the calls we receive for a number of years, but this does not contain any personal data.
We use a third-party provider, Audiense, to manage our social-media interactions. If you send us a private or direct message via social media, it will be stored by Audiense for three months. It will not be shared with any other organisations.
We see all this information and decide how we manage it. For example, if you send a message via social media that needs a response from us, we may process it in our case management system as an enquiry or a complaint.
We use a third party email provider, Google, for our company email accounts. Google uses Transport Layer Security (TLS) to encrypt and protect email traffic in line with government guidance on email security.
Online contact form
Our website has a contact form for the convenience of users who wish to contact us directly from our website. By completing the fields on the form and submitting your communication by this method, we assume that you wish to receive a response from a relevant member of our team. Your enquiry may be shared internally in order to identify the best-placed person to respond on behalf of the organisation.
VISITORS TO OUR WEBSITE
When you visit stage2.waac2.opensure.net, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
If we do collect personal data through our website, we’ll be upfront about this. We’ll make it clear when we collect personal information and we’ll explain what we intend to do with it.
Our website utilises an internal search facility. Search queries and results are not stored or logged. No identifiable personal information is collected by the use of the search facility.
Purpose and legal basis for processing
The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.
What are your rights?
As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.
For more information on your rights, please see ‘Your rights as an individual’.
VISITORS TO THE OFFICE
We meet visitors at our office, including:
- job applicants
- suppliers, and
There is no reception for our office building, but there is a shared entrance foyer with closed-circuit television (CCTV) which operates for safety and security purposes. The CCTV is not operated by us, so we are not the controller. It is under the control of the building landlord.
We have Wi-Fi in our office for the use of staff and visitors. We’ll provide you with the address and password. We don’t ask you to agree to terms, just to the fact that we have no responsibility or control over your use of the internet while you are on site, and we don’t ask you to provide any of your information to get this service.
REASONS FOR CONTACTING US
We outline below our specific policy with regards to the most common reasons for contacting us:
- Making an enquiry
- Applying for a job, internship or placement
- Attending an event, seminar or workshop
- Communicating with us as a business
1. Making an enquiry
When you contact us to make an enquiry, we collect information, including your personal data, so that we can respond to it as requested by you.
We need enough information from you to answer your enquiry. If you telephone the office, we won’t make an audio recording of it and we won’t usually need to take any personal information from you. But we may make notes to provide you with a further service as required.
If you contact us via email or post, we’ll need a return address for response.
2. Applying for a job, internship of placement
Our purpose for processing this information is to assess your suitability for a role you have applied for.
We’ll use all the information you provide during the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress your application. We’ll use the other information you provide to assess your suitability for the role.
We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it may affect your application if you don’t.
If you use our online application system, your details will be collected by a data processor on our behalf (please see below).
We ask you for your personal details including name and contact details. We’ll also ask you about previous experience, education, referees and for answers to questions relevant to the role. Our recruitment team will have access to all this information.
Our hiring managers shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.
We may ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; attend an interview; or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by us.
If you are unsuccessful after assessment for the role, we may ask if you would like your details retained in our talent pool. If you say yes, we would proactively contact you should any further suitable vacancies arise.
If we make a conditional offer of employment, we’ll ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We’ll ask you for the contact details of your referees (if you have not already supplied these as part of your application). We will contact your referees directly to obtain references.
After your start date
We must confirm the identity of our staff and their right to work in the United Kingdom, and seek assurance as to their trustworthiness, integrity and reliability.
If we make a final offer, we’ll also ask you for the following:
- proof of your identity – you will be asked to attend our office with original documents; we’ll take copies
- proof of your qualifications – you will be asked to attend our office with original documents; we’ll take copies
- a criminal records declaration to declare any unspent convictions
- bank details – to process salary payments
- emergency contact details – so we know who to contact in case you have an emergency at work
Internships and placements
We also offer opportunities for people to come and work with us on an internship or placement. We accept applications from individuals or organisations who think they could benefit from their staff working with us.
Applications are sent directly to us. Once we have considered your application, if we are interested in speaking to you further, we’ll contact you using the details you give.
We may ask you to provide more information about your skills and experience or invite you to an interview.
If we do not have any suitable work at the time, we’ll let you know but we may ask if you would like us to retain your application so that we can proactively contact you about possible opportunities in the future. If you say yes, we’ll keep your application for six months.
How we make decisions about recruitment
Final recruitment decisions are made by our Founding Director. We take account of all the information gathered during the application process.
You can ask about decisions on your application by contacting our Founding Director via email@example.com or 01273 921866.
Use of data processors
If you are employed by us, relevant details about you will be provided to Craker Business Solutions who provide our accountancy services and AFH Payroll who provide our payroll services. This will include your name, bank details, address, date of birth, National Insurance Number and salary.
Likewise, your details will be provided to the People’s Pension who is the administrator of our company pension scheme, of which we are a member organisation. You will be auto-enrolled into the pension scheme and the details provided to the People’s Pension will be your name, date of birth, National Insurance number and salary. Your bank details will not be passed to the People’s Pension at this time.
3. Attending an event seminar or workshop
Our purpose for collecting this information is so we can facilitate the event and provide you with an acceptable service.
If you wish to attend one of our events, you will be asked to provide your contact information including your organisation’s name and, if offered a place, information about any dietary requirements or access provisions you may need. We may also ask for payment if there is a charge to attend.
We use this information to facilitate the event and provide you with an acceptable service. We also need this information so we can respond to you.
If you are not successful in securing a place, we’ll let you know and hold your details on a reserve list in case a place becomes available.
If you are allocated places at an event, we’ll ask for information about any dietary/access requirements. We don’t share this information in any identifiable way with the venue, and we delete it after the event.
We rely on your consent to process the personal data you give us to facilitate the event. This means you have the right to withdraw your consent at any time. If you do that, we’ll update our records immediately to reflect your wishes.
We use data processors to help facilitate the events, and we may sometimes charge a fee to attend an event. If this happens, our communications about the event will provide details of the data processor we use to collect payments.
4. Communicating with us as a business
We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business.
If the interactions relate to suppliers, contracts, buildings management, IT services etc., the legal basis is article 6(1)(c) of the GDPR for any legal obligation or article 6(1)(f) because the processing is within our legitimate interests as a business. [Ends]
[Updated: 19 June 2018]