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Introduction
 
Welcome to the site (“the Site”) which is managed and owned by Alcumus HSE Limited, on behalf of our client (“Client”) in accordance with the contract for services we have in place with the Client. This is the Site privacy notice.
 
Alcumus HSE Limited (“HSE”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.


1. Important information and who we are Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of the Site (both as an authorised user of the Site and as a representative of our Client), including any data you may provide through the Site. This privacy notice also sets out your legal rights.
 
This Site 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.
 
Contact details
 
We are Alcumus HSE Limited (Company Number 07511553) with our registered office at Axys House, Heol Crochendy, Parc Nantgarw, Cardiff, Wales, CF15 7TW. We are directly owned by Alcumus Holdings Limited (Company Number 06955372), and our ultimate parent company is Alcumus Group Limited (Company Number 09793309), both of the same registered office.
 
We have appointed a voluntary data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Karl Mrosek, on dpo@alcumusgroup.com.
 
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
 
This version was last updated on 31 October 2018. Historic versions can be obtained by contacting us.
 
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
 
The Site does not include any links to third-party websites, save for where the Client has requested links as part of the configuration of the Site. We do not control these third-party websites and we are not responsible for any privacy notices displayed on them. We therefore encourage you to read the privacy notice of each website you visit via a link from the Site. The Site does contain a link to our main company website www.alcumusgroup.com.

2. 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, including:
 

  • Identity Data includes first name, maiden name, last name, username, and title.

  • Contact Data includes billing and operational address(es), email address and telephone numbers.

  • 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 the Site.

  • Usage Data includes information about how you use the Site.

  • Communications Data includes your communication preferences in receiving service communications from us.

  • We also collect, use and share Aggregated Data such as demographic data for the purposes of monitoring usage and trend analysis across our client base. 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 Site 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.

 
Information you upload to the Site

We provide access to the Site to you in accordance with a contract for provision of services that we have in place with our Client (who for the avoidance of doubt, has provided you with authorisation to access and use the Site as an authorised user). In relation to any personal data that you upload or record on the Site, our Client is the data controller in respect of such personal data and this means that it remains primarily responsible for such personal data (e.g. your customers’ or employees’ data).
 
We process this personal data on behalf of our Client in order to perform the services for our Client and provide access to the Site to you and other authorised users. The precise purpose for which the personal data is processed will be determined by the scope and specification of our terms of business with our Client, and by any applicable laws.
 
It is always our Client’s obligation to ensure that the data subjects of the personal data you (or any authorised user) uploads to the Site understand that their personal data will be processed by us in accordance with our contract with our Client.

Information we upload to the Site
 
There may be instances where we upload personal data to the Site on the instructions of a Client representative in order to perform and provide the services. We will act as data processor in relation to this personal data, and our Client will be primarily responsible for it. We will of course act at all times act in accordance with this privacy notice.
 
If you fail to provide personal data
 
If you fail to provide personal data when requested, we may not be able to perform the contract we have with our Client..

3. 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 Data by uploading it to the Site, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
 
  • create an authorised user account on the Site;

  • subscribe to our publications;

  • request marketing to be sent to you

  • give us some feedback.

 
Automated technologies or interactions. As you interact with the Site, 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.

4. 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 have with our Client.

  • 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.

  • Where we need to comply with a legal or regulatory obligation.

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 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 register you as an authorised Site

(a) Identity Data
(b) Contact Data

Performance of a contract with our Client

To manage our relationship with you as an authorised user of the Site under our contract with our Client which will include:

(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a user satisfaction survey

(a) Identity Data (b) Contact Data (c) Communications Data

(a) Performance of a contract with our Client
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how authorised users use the Site and/or our products/services)

To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring the Site usage and compliance with the contract we have in place with our Client)

(a) Identity Data (b) Contact Data (c) Technical Data

(a) Necessary for our legitimate interests (for running our business, administration and IT services, network security, to prevent fraud and in the context of a business reorganisation restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant the Site content to you

(a) Identity Data
(b) Contact Data
(c) Usage Data (d) Communications Data
(e) Technical Data

Necessary for our legitimate interests (to study how authorised users use the Site, to grow our business and to inform our marketing strategy)

To use data analytics to improve the Site, services, marketing, customer relationships and experiences

(a) Technical Data
(b) Usage Data

Necessary for our legitimate interests (to define types of authorised users of the Site, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)

Marketing and Opt Out 

We do not undertake marketing, promotions or competitions via the Site. This may be undertaken via other means. You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your usage of the Site, service experience or other transactions.

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 require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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.
 

5. 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.
 

  • Other companies in the Alcumus Group of companies acting as joint controllers or processors and which provide IT, finance and/or system administration services.

  • External third parties including: 

    • UK-based service providers acting as processors who provide IT and system administration services (specifically Rackspace, a managed hosting service, and Clearstream, a managed data centre).

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide legal, insurance and accounting services.

    • HMRC, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

    • Third parties to whom we may choose to sell or merge parts of our business. 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.
       

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. We limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality. 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.

 
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.

7. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

8. Data Retention
How long will you use my personal data for?

 
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 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.
 
Details of retention periods for your personal data are available on request by contacting us.
 
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.

9. Your legal rights

Under certain circumstances, you have legal rights 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 your personal data. 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: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object to processing (see below); (c) where we may have processed your information unlawfully; or (d) 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.
 
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 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 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.
 
If you wish to exercise any of the rights set out in this privacy notice, please contact us.