This is an important notice regarding your privacy and the way in which Tech 21 UK Limited (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to our customers, suppliers, contractors, sub-contractors and applicants generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of applicable privacy legislation, the data controller is Tech 21 UK Limited of Syds Quay, Eel Pie Island, Twickenham, TW1 3DY. Our company registration number is 05630013.
Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and this policy, and can be contacted by email at firstname.lastname@example.org. Any questions about the operation of this policy or any concerns that the policy has not been complied with should be referred in the first instance to the Data Protection Compliance Manager.
1. What information do we hold about you?
Personal contact details such as the name, title, address, telephone number and email address;
Recruitment information (including, for example, passport or visa information and other personal information included in an application form, CV or cover letter as part of your application for employment with us).
Personal information provided to us by our recruitment partners in relation to your application for employment with us.
Personal information provided by you to us during the course of your application, for example, your application video.
Personal information gathered during your application process, including psychometric test data (which are tests administered by our third party test supplier).
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Payment information such as credit/debit card number, expiration date, security code (CVV), name as it appears on the card and address the card is registered to.
Other personal information you provide to us via our website, for example, by using the “Contact us” form.
Personal information provided to us by the third party service providers we work with, for example, payment services, analytics providers and third party companies providing us with marketing assistance.
Contact details such as your name, title, business telephone number and business email address or personal telephone number and personal email address (if you provide them to us).
Information you provide or we collect during our interactions with you or your employer, such as how long we have done business with you, or how long you have worked at your company.
Other personal information you provide to us via our website, for example, by using the “Contact Us” page on our website.
Contractors and Suppliers
Personal details such as your name, address, bank account information, email address and telephone number.
If you visit our offices, images and video which are recorded by the CCTV system in operation there. This system does not record audio.
Information gathered when you visit our offices via our visitor registration system including name, digital signature, photograph, emergency contact details, company, vehicle registration, telephone number and email address.
Any personal information you provide to us during your interactions with us.
Any personal information about you provided to us during our interactions with you, your employer or a third party.
Any personal information you provide to us via our website, for example, by using the “Contact us” page on our website.
Information provided to us by third party service providers we work with, for example, payment service providers, analytics providers or providers assisting us with marketing and communication solutions.
2. How will we use information about you and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
Where you have provided us with your consent for us to do so.
Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you.
Where we need to comply with a legal obligation to which we are subject.
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest.
More specifically, we will use your personal information in the following circumstances:
To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
To keep a record of your application – in pursuit of our legitimate interests in the event we wish to offer to place you in another role within our organisation.
To carry out right to work checks – to comply with a legal obligation to which we are subject.
Your contact details to facilitate your purchase or proposed purchase with us – to perform the contract with you or to take steps to enter into a contract with you.
Your contact details to provide you with information on our products and services. This may include technical information – to perform the contract with you or to take steps to enter into a contract with you. This may also include marketing information – where you have provided us with your consent for us to do so.
To manage your customer account – to perform the contract with you or to take steps to enter into a contract with you or in pursuit of our legitimate interests (to enhance or modify our services).
Your personal details and payment information to identify and prevent fraud - in pursuit of our legitimate interests (to prevent fraud for you and for us).
Dealing with your enquiry made via the “Contact Us” page on our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.
Your contact details – in pursuit of our legitimate interests (to facilitate business between your organisation and ours).
Your contact details to provide you with further information on our products and services. This may include technical information and / or marketing information – in pursuit of our legitimate interests (keeping you informed about our products, services and business updates).
To ensure our offices are kept secure – in pursuit of our legitimate interests (office security and evidence).
Health and safety purposes – to comply with a legal obligation.
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
To transfer to third party service providers – in pursuit of our legitimate interests (outsourcing for effectiveness and efficiency).
To contact you if we wish to use your information for a purpose not set out in this policy – to comply with a legal obligation.
3. What happens if there is a change of purpose?
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4. Which type of third parties might we share your personal information with?
We require third parties to respect the security of your information and to treat it in accordance with the law. For example, where instruct third party services providers we carry out due diligence on those providers to ensure they treat your information as seriously as we do.
We may share your information with the following types of third parties:
Technical support providers, for example, assisting with our website.
Recruitment agencies assisting us with employment related matters.
Professional advisers such as lawyers, accountants and business analysts.
Providers which assist us with marketing by, for example, helping us send out marketing mailshots.
Providers which help us sell our products by, for example, providing us with payment collection services or eCommerce platforms.
Providers which help us collate and organise information effectively and securely.
Providers which help us by providing customer service solutions, for example, ticketing support.
Providers which help us with logistics and delivery solutions.
Providers which help us generate and collate reviews, rations questions and answers in relation to our products.
Third party software hosting companies which provide us with software solutions.
Providers which host our servers in their data centres (these are all within the UK).
5. Data retention
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature, and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months.
The period during which we keep your information will depend on a number of things. For example:
if you have consented to receiving marketing information we will keep your contact details for as long as we still have your consent;
if you have an account with us, we will keep your information until you delete that account or it has been inactive for 50 months;
where your product has a warranty, we will keep your details for as long as the warranty period;
We will keep your information for as long as our organisations do business together or for as long as we have a commercial interest in holding that information, for example, doing business in the future, inviting you to our events and providing you with our product information where you have not opted out from this.
Any data collected through our visitor registration system is stored for 7 days only.
Any videos or images captured by our CCTV system are stored for 90 days.
6. Where we store your personal information
Electronic versions of the information you provide to us or we collect about you are stored on our servers within the UK.
Where we use third party service providers to assist us, your information may also be stored in accordance with their practices and procedures. We require third parties to respect the security of your information and to treat it in accordance with the law.
If your data is transferred outside of the EEA, we will take steps to ensure your personal information is adequately protected by, for example, ensuring appropriate safeguards are in place governing the transfer.
7. Rights of access, correction, erasure, and restriction
Your rights in connection with your personal information
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 the 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 stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
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.
8. No fee usually required
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.
9. 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 the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
10. Right to withdraw consent
Where we are providing you with marketing information, you can also change your marketing preferences via your online account (if you have one with us) or by using the unsubscribe button at the bottom of our marketing emails to you. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
11. What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).
12. Right to complain
You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (email@example.com).
13. Changes to this privacy notice
We may change, modify, add or remove portions of this policy at any time, and any changes will become effective immediately.