Last updated: 21 October 2019
APTIM and ("we", "us", or "our") refers to APTIM-Solutions Limited.
Personal data is any information relating to an identified or identifiable living person. When "you" or "your" are used in this statement, we are referring to the relevant individual who is the subject of the personal data. APTIM processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this policy.
Our processing activities
APTIM processes personal data about contacts (existing and potential clients and/or individuals associated with them) using a customer relationship management system (CRM).
The collection of personal data about contacts and the addition of that personal data to our CRM is initiated by an APTIM user and will include name, employer name, contact title, phone, email and other business contact details. In addition the CRM may collect data from the APTIM email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between APTIM user and contacts or third parties.
Use of personal data
- administering, managing and developing our business services;
- managing our relationship with clients;
- developing our business and services;
- analysing and evaluating the strength of interactions between us and a contact;
- performing analytics, including producing metrics on trends, relationship maps, sales intelligence and progress against business goals;
- maintaining and using IT systems;
- hosting or facilitating the hosting of events;
- administering and managing our website and systems and applications;
- unless we are asked not to, we use business contact details to provide information that we think will be of interest about us and our services. E.g. industry updates and insights, other services that may be relevant and invites to events.
APTIM does not sell or otherwise release personal data contained in the CRM to third parties for the purpose of allowing them to market their products and services without consent from individuals to do so.
Personal data will be retained on the CRM for as long as we have, or need to keep a record of, a relationship with a business contact, which is for the duration of our relationship with a contact or their organisation.
Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
Collection of personal data
Our policy is to collect only the personal data necessary for agreed purposes and we ask our clients only to share personal data with us where it is strictly needed for those purposes.
Individuals who use our applications
We provide external users access to various applications managed by us. Such applications will contain their own privacy statements explaning why and how personal data is collected and processed by those applications.
Others who get in touch with us
We collect personal data when an individual gets in touch wish us with a question, complaint, comment or feedback. This includes data such as name, contact details and contents of the communication. In these cases, the individual is in control of the personal data shared with us and we only use the data for the purpose of responding to the communication.
We collect personal data conerning our own personnel as part of the administration, management and promotion of our business activities.
We carry out pre-employment screening checks as part of our on-boarding process. Depending on the role this may include criminal records checks.
Collection of personal data
- contact details;
- areas of interest;
- username and password to apply for a role;
- CV, experience, eduction, academic and professional qualifications;
- information provided as part of interviews and assessments;
- social mobility data;
- diversity and equality opportunities data;
- pre-employment screen information if your application is successful;
- bank account details if your application is successful.
Collection of personal data
We collect and process personal data about our suppliers (including subcontractors and individuals associated with our suppliers and subcontractors) in order to manage the relationship, contract, to receive services from our suppliers and, where relevant, to provide services to our clients. The personal data is generally business card data and will include name, employer name, phone, email and other business contact details and the communications with us.
Use of personal data
Visitors - physical and virtual
Visitors to our offices
Our offices may have CCTV and building access controls which may be operated by third parties.
Visitors to our website
Our websites do not collect or compile personally identifying information for sale to non-APTIM parties for their marketing purposes.
We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system is built to comply with the requirements of ISO/IEC 27001:2013. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
Sharing personal data and locations
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with out data protection, confidentiality and security standards.
We use third parties located in other countries to help us run our business. As a result, personal data may be tranfserred outside the countries where we and our clients are located. This includes to countries outside the European Union and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all perosnal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside of the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and managemennt, data anlaysis, data backup, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
|Google Ireland Limited||Business applications||Data centres located in a number of locations around the world|
|Microsoft Limited||Azure cloud services||Data centres located in a number of locations around the world|
|Freeagent||Accounting and invoicing services||Europe data centres utilised|
|Mailchimp||Email marketing platform||Data centres located in a number of locations around the world|
Data controller and contact information
Individuals' rights and how to exercise them
Individuals have certain rights over their personal data and controllers and responsible for fulfilling these rights.
Individuals' rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complain with a supervisory body.
Please see further information about these rights, when they are available and how to exercise them below.
Your right of access to personal data
Your right to rectification / amendment of personal data
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
To update personal data submitted to us, you may email us at firstname.lastname@example.org or, where appropriate, contact us via the relevant website registration page or directly amend the personal details held on relevant websites or applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates as appropriate based on your updated information.
Your right to erasure / right to be forgotten
- the personal data are no longer necessary in relation to the purpose for which they were collected and processed;
- our legal grounds for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
- our legal grounds for processing is necessary for legitimate interests pursued by us or a third party, you object to our processing and we do not have overriding legitimate grounds;
- you object to our processing for direct marketing purposes;
- your personal data have been unlawfully processed; or
- your personal data must be erased to comply with a legal obligation to which we are subject.
To request deletion of your personal data, please email us at email@example.com
Your right to restrict processing
- for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data;
- your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
- your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; or
- for a period enabling us to verify whether the legitimate grounds relied on us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
To restrict our processing of your personal data, please email us at firstname.lastname@example.org
Your right to object to processing
- our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
- our processing is for direct marketing purposes.
To object to our processing of your personal data, please email us at email@example.com
Your right to data portability
You have a right to receive your personal data provided by you to us and have the right to send the data to another organisation (or to ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
To exercise your right to data portability, please email us at firstname.lastname@example.org
Your right to withdraw consent
We hope that you won't ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to email@example.com. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, please of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner's Office (ICO) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us at firstname.lastname@example.org in the first instance.