Introduction

Aptis Consulting Limited (“Aptis Consulting”) 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 when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice (at the very bottom).

Purpose of this privacy notice

This privacy notice aims to give you information on how Aptis Consulting collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive more information from us or register to attend an event.

This website is not intended for children and we do not knowingly collect data relating to children.

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.

Controller

Aptis Consulting Limited is the controller and responsible for your personal data (referred to as “Aptis Consulting”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity: Aptis Consulting Limited

Email address: enquiries@aptisconsulting.co.uk

Postal address: 24 Picton House, Hussar Court, Havant, PO7 7SQ, UK

Telephone: 0208 133 0853

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

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.

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 and gender.

Contact Data includes address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, 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.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We 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). Nor do we collect any information about criminal convictions and offences.

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 and 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:

subscribe to our service or publications;

request marketing to be sent to you;

enter into any of our competitions or prize draws

register to attend one of our events; or

give us some feedback.

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. Please see our cookie policy for further details.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties: analytics providers such as Google based outside the EU, advertising networks and search information providers;

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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). In this context, “legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service 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).

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. If we expressly tell you that we are relying on consent as a legal basis for processing your personal data, you can withdraw consent at any time by contacting us at enquiries@aptisconsulting.co.uk.

Purposes for which we will use your personal data

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 at enquiries@aptisconsulting.co.uk 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 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 take a survey (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 and to study how clients use our 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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you         (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical        Necessary for our legitimate interests (to study how clients use our website and services, to develop them, to grow our business and to inform our marketing strategy)

To administer any competitions or prize draws that we may run from time to time             (a) Identity

(b) Contact

(c) Profile

(d) Usage             Necessary for our legitimate interests (to run competitions and prize draws which are of interest to our clients and to promote Aptis Consulting)

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

(b) Usage             Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Third-party marketing

We won’t share your personal data with any company outside Aptis Consulting for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at enquiries@aptisconsulting.co.uk.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy

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 contact us at enquiries@aptisconsulting.co.uk.

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.

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:

Service providers acting as processors based inside and outside the EEA who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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.

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 instructions.

International transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

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 at enquiries@aptisconsulting.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 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.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it 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.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

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.

If you wish to exercise any of the rights set out above, please contact us at enquiries@aptisconsulting.co.uk.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

 

Candidate Privacy Notice

In the event we ask for applications for employment opportunities with us, we need to collect and use certain information about you so that we can manage our relationship with you. Some information we collect and use will be personal data.

Aptis Consulting Limited is a “data controller”. This means that we decide how we hold and use personal information about you.

We think that it is important to be transparent about how we collect and use your personal data and are committed to protecting the privacy and security of the information we hold about you. This privacy notice provides more information about how we do this and provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

This notice applies to all prospective Aptis Consulting employees, workers and contractors. We may update it at any time.

Data protection principles

used lawfully, fairly and in a transparent way;

collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

relevant to the purposes we have told you about and limited only to those purposes;

accurate and kept up to date;

kept only as long as necessary for the purposes we have told you about; and

kept securely.

What personal data do we collect?

We will collect, store and use a range of personal data about you. This includes the following:

the information you have provided to us in your curriculum vitae and covering letter;

the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;

test results for tests included as part of the recruitment process;

your video interview;

any information you provide to us during an interview.

We may also collect, store and use the following types of more sensitive personal information:

information about your race or ethnicity, religious beliefs, sexual orientation and political opinions/affiliation/political party membership;

information about your health, including any medical condition, health and sickness records; and

information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates in a variety of ways. For example, from:

you directly. For example, during interviews, meetings or assessments;

forms or other correspondence provided by you. For example, application forms, your CV, or other forms completed during the recruitment process;

your identity documents, such as your passport and/or driving licence.

We may also collect personal data about you from third parties, such as:

your named referees;

recruitment agencies and other bodies, for example High Fliers Publications Limited who compile the Times Top 100 Graduate Employers list and the Cambridge class list;

the Disclosure and Barring Service in respect of criminal convictions;

background check providers;

credit reference agencies (as permitted by law); and

publicly accessible data from third parties, including LinkedIn and Facebook.

Why do we need to process your personal data?

We will need to collect, store and use personal data about you for a number of reasons:

to perform our obligations under your contract of employment. For example, we need to process your personal data to pay you your salary and provide your benefits

to ensure that we comply with our legal obligations. For example, we are required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable you to take holiday

to pursue legitimate interests of our own, or those of third parties. When we do this, we always make sure that your fundamental interests and rights do not override those interests and

because you have given your consent for us to do so.

The examples given below do not form an exhaustive list of purposes for which your personal data will be processed, and we reserve the right to add to them at any time.

Situations in which we will use your personal data

The situations in which we will process your personal data are listed below:

To comply with our legal obligations, including:

checking you are legally entitled to work in the UK;

dealing with legal disputes involving you, or other candidates, employees, workers and contractors;

ascertaining your fitness to work;

complying with health and safety obligations;

complying with our obligations to notify law enforcement about criminal activity or convictions;

complying with our obligation to make reasonable adjustments for employees, workers and contractors who have a disability; and

to prevent fraud.

To pursue legitimate interests of our own, or those of third parties, including:

assessing your skills, qualifications, and suitability for the role;

carrying out background and reference checks, where applicable;

communicating with you about the recruitment process;

keeping records related to our hiring processes.

In each of the above cases, the legitimate interest is to allow candidates to apply for a role at Aptis Consulting and to ensure that we employ suitable candidates.

Special categories of personal data and criminal convictions

”Special categories” of personal data require higher levels of protection.

We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances:

where we need to carry out our legal obligations; and

where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

where it is needed in relation to legal claims or where it is needed 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 will use your particularly sensitive personal information in the following ways:

we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview;

we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

we may also use information relating to criminal convictions where the law allows us to do so. 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.

If you fail to provide personal information

If you fail to provide information 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. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Who has access to your personal data?

Your information will be shared internally, including with HR, recruitment and finance in each case if and where access to the data is necessary for performance of their roles.

We may also share your personal data externally with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. For example, we may share your personal data with third parties in order to:

administer our recruitment process;

obtain pre-employment references from other employers or referees;

obtain employment background checks from third-party providers;

obtain necessary criminal records checks from the Disclosure and Barring Service;

and obtain security clearance for you (if applicable).

Where we share your personal data with third parties, we require that they respect the security of your data and 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. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

How do we protect your personal data?

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

We have also 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 instructions and they are subject to a duty of confidentiality.

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

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long do we keep your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After this period, we will securely destroy your personal information.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal data in accordance with our retention policy.

We may retain your personal information on file on the basis that a further opportunity may arise in future and we may wish to consider you for that. We will only do this if you have given your explicit consent for us to retain your details for this purpose as part of the recruitment process.

What are your rights?

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact HR in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

During the recruitment process, you may be subject to automated decision making in the marking of your test scores.

Where you are subject to automated decision making, you will be expressly notified in advance. In these cases, you also have the right to request a reconsideration of the result of the automated decision making by submitting a reconsideration request to enquiries@aptisconsulting.co.uk.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Policy last reviewed and updated 16th of December 2020