About Us

Our Privacy policy

Introduction

Acton Banks Ltd with its registered office at Gresham Chambers, 14 Lichfield Street, Wolverhampton, West Midlands, WV1 1DG (company number 05840738) respects your privacy and is committed to protecting your Personal Data.

It is important that you read this Privacy Policy together with any other privacy notices/policies or fair processing notices/policies 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 Policy supplements the other notices and is not intended to override them.

Please use the Glossary that can be found at the end of this Policy to understand the meaning of some of the capitalised terms used in this Policy like Personal Data.

Purpose of this privacy notice

This policy will inform you as to how we collect and process your Personal Data when you register, do training, provide services to us, work with us or use our website. This policy also tells you about your privacy rights and how the law protects you.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. For the avoidance of doubt, we are required by law to issue this notice to all individuals for which we hold personal data and the issuing of this notice does not alter the terms of any contract we have agreed with you and does not alter the status under which we have contracted with you.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24.05.18. 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

Our 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 policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together including the following:

Identity Data

includes first name, maiden name, last name, marital status, title, date of birth, gender.NI Number and photographs.

Registration application data

includes references, training certificates, application forms.

ID verification

includes copies of your passport, drivers licence, utility bills & birth certificates.

Contact Data

includes address, email address and telephone numbers.

Financial Data

includes bank account details.

Technical Data

includes internet protocol (IP) address, your login data, 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 our website.

Profile Data

your username and password, your interests, preferences in jobs and/or positions, level of experience you have, feedback and survey responses.

Usage Data

includes information about how you use our website, products and services.

Payment information

We also collect various special categories of personal data following registration about you such as Enhanced DBS information, Biometric card copies & Health data (such as immunisations) as required by law or for reasons of performance of our contract with you.

Please note that the above is a list of examples of information that we may hold on you and does not mean that we do hold this information on you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

How we collect data from you

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

apply for opportunities listed on our website;

apply for opportunities via a job portal;

register for an account on our website;

request information or communicate directly from our website;

attend in person for registration;

attend in person for a training course;

complete an online training course;

complete a phone based part-registration;

attend a blood test.

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 server logs and other similar technologies

Purposes for which we will use your personal data

We will process/use your Personal Data when you engage directly with us or visit our website for the following reasons:

To verify your identity;

To verify that you have valid right to work in the UK;

To confirm that you meet all our compliance standards before providing your services;

To help us perform our contractual obligations to you;

To ensure accuracy of payment;

To process payment;

If we pay you directly to ensure that valid NI & tax deductions are being made;

To provide you with opportunities to earn and provide your services if registered;

To provide training opportunities to you;

To administer training to you;

To confirm fitness to practice in certain settings;

To ensure that content from our website is presented in the most effective manner for you and for your computer;

To provide you with information regarding our services that you request from us and with information about other services we offer that are similar to those that you have already enquired about;

To create your account if you register with us as a member and to update your membership records and run all membership accounts;

To communicate with you in general (including, for example and without limitation, via email, post or SMS) in order to provide our services, including sending information about changes to the services that we offer, any special events, opportunities to re-register or refer other people;

To administer our website and for internal operations, such as troubleshooting, data analysis, testing, research and survey purposes;

To carry out our obligations arising out of any contracts entered into with you;

To allow you to participate in any interactive features of our website including applying for jobs;

To protect our others rights property or safety;

Where it is necessary for our legitimate interests (or those of a third party), to perform the contract we have entered into with you and where it is required to comply with legal obligations.

Legal basis for processing your Personal Data

We will only process your Personal Data when the law allows us to. The legal basis for processing your Personal Data for the above reasons will typically be one of the following:

where we need to perform the contract we are to enter into or have entered into with you;

where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or

where we need to comply with a legal or regulatory obligation.;

when we have your consent.

Who do we share your Personal Data with and why?

We may have to have to share your Personal Data with the following;

those in the business on a basis for legal, business or administrative purposes;

service providers who help us run the website and our IT services, solely for the purposes of running our website or administering our business;

our clients who require certain data for legal compliance and obligations as set out by the CQC;

organisations processing your invoice or payment on your behalf;

authorities and official bodies, where we are under a legal or regulatory obligation;

our professional advisers for the purposes of seeking legal or other professional advice;

third parties in order to enforce or apply any agreements between you or to protect the rights, property, or safety of us or our customers and others;

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 of ownership happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.

Transfer and Storage of Your Personal Data

We currently do not transfer or store your Personal Data outside the European Economic Area (EEA). If this changes and we do need to store and/or transfer your Personal Data outside the EEA this Policy will be updated.

If we transfer and/or store your Personal Data outside of the EEA, we will ensure a similar degree of protection is afforded to it as it is within the EEA by ensuring at least one of the following safeguards are 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.

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.

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.

Please Contact Us (using the details provided below) if you want further information on the specific mechanism used by us when transferring and/or storing your Personal Data outside of the EEA.

Data Security

We have put in place appropriate administrative, technical and physical 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.

Of course, we cannot absolutely guarantee the security of the internet or external networks and any online communications (e.g. information provided by email or through our website are at your own risk).

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential and we ask that you do not share this password with anyone.

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 requirements. This means that Personal Data is destroyed or erased from our systems when no longer required.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data, such as:

Request access to your Personal

(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 your 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 the 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 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.

Requests 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.

Right to 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 find out more about the above rights or to exercise any of the above rights, please contact us by e-mailing gdpr@actonbanks.co.uk. We will 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. If this case, we will notify you and keep you updated.

Please keep in mind there are exceptions to the rights set out above, though we will always try to respond to your satisfaction, there may be situations where we are unable to do.

Queries and Complaints

If you have any queries or questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at gdpr@actonbanks.co.uk.

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.

Glossary

Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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).

Perform/Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation: means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Processing:Doing anything with Personal Data; this includes collecting it, storing it, accessing it, combining it with other data, sharing it with a third party, or even deleting it.

Personal Data: 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).

EEA:The EEA currently includes all European Union member states and Iceland, Liechtenstein and Norway.



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