GDPR Privacy Policy

Last Updated: July, 30th 2020

Phoenix51

Phoenix 51 Limited is committed to protecting the information you share with us. As an Assessment Platform, we will collect and share certain information about you as part of providing an Employee/Recruitment Assessment Service. We may collect your details as a client, supplier, or website user.

Phoenix 51 Limited is a company registered in England & Wales (no. 12176947). Our registered address is; Building One, Chalfont Park, Gerrards Cross, Buckinghamshire, SL9 0BG

We are registered with the Information Commissioners Office (ICO) under registration number ZA785644 a data controller. We process data as a controller for our employees, clients and suppliers. We process data as a processor for our clients.

This Privacy Policy is effective from 01st May 2018 and complies with the General Data Protection Regulations (GDPR) (Regulation (EU) 2016/679) that came into force across the EU on 25th May 2018.

1. What information do we collect about you?

As a Client, the information we collect may include the following:

• Name

• Job Title

• Address

• Email and phone contact details

• Records of interactions including meetings, emails and calls

• Usage of services

• Information from third parties regarding insurance, credit reference, fraud, debt

• Personal information relating to hobbies, interests and pastimes

As a Supplier, the information we collect may include the following:

• Name

• Job Title

• Address

• Email and phone contact details

• Records of interactions including meetings, emails and calls

• Information from third parties regarding insurance, credit reference, fraud, debt

• Your marketing preferences

2. How will we use the information about you?

As a Client, we will use your information for the following purposes:

• Provide you with our services

• Collecting your data

• Processing and storing your data

• Communicating with you

• Managing any aspect of providing the service including customer service

• Maintaining a record of the services we have provided to you

• Carrying out credit reference and fraud checks

• To comply with legal and regulatory obligations, requirements and guidance

• For the establishment, exercise or defence of legal claims

• Sharing your details with third-parties to fulfil accounting, invoicing and payroll

• Improve our services, internal performance, training and standards

As a Supplier, we will use your information for the following purposes:

• Purchasing your services

• Collecting your data

• Processing and storing your data

• Communicating with you

• Managing any aspect of purchasing your services

• Maintaining a record of the services you have provided to us

• Carrying out credit reference and fraud checks

• To comply with legal and regulatory obligations, requirements and guidance

• For the establishment, exercise or defence of legal claims

• Sharing your details with third-parties to fulfil accounting, invoicing and payroll

• Improve our services, internal performance, training and standards

3.    How do we collect information about you?

As a Client we may collect your information from the following sources, amongst others:

• You directly

• Your colleagues

• Via our employees’ business development activities

• Social media including LinkedIn

• Our Clients and/or suppliers

• Third parties such as credit reference agencies

• Industry events & publications

• From contracts we sign with you

• From you contacting us to market your services

• From your colleagues as part of our contractual relationship

As a Supplier we may collect your information from the following sources, amongst others:

• You directly

• Your colleagues

• Via your employees’ business development activities

• Social media including LinkedIn

• Our Clients and/or suppliers

• Third parties such as credit reference agencies

• Industry events & publications

4.     Why we process the information including our legal basis?

We process your data to complete our activities as an Assessment Platform. The below explains the lawful basis we use to process your data.

As a Client:

• We believe it is in our legitimate interest to collect and process your data where we believe you would be interested in our services. For example; if you are a HR Manager who is involved in making recruitment/employee performance decisions.

• At times we will request your explicit consent to process and store your data. Where this is required we will inform you at the time and provide you with clear information about what you are consenting to. For example; you subscribing to our newsletter about industry news & products.

• Where we establish a contractual relationship with you and/or your employer we will collect and process your data to enable us to meet these contractual agreements.

• Where we are required by regulatory and statutory obligations we will retain your data to meet these legal requirements. For example; tax, fraud/crime, data protection.

As a Supplier:

• We believe it is in our legitimate interest to collect and process your data where we may be interested in purchasing your service. For example; a stationary provider or accountants.

• At times we will request your explicit consent to process and store your data. Where this is required we will inform you at the time and provide you with clear information about what you are consenting to. For example; you subscribing to our newsletter about industry news & services.

• Where we establish a contractual relationship with you and/or your employer we will collect and process your data to enable us to meet these contractual agreements.

• Where we are required by regulatory and statutory obligations we will retain your data to meet these legal requirements. For example; tax, fraud/crime, data protection.

5. Who we share your personal data with?

We share your information with selected third-parties. These include but are not limited to:

• Clients;

• Supplier;

• Service Providers;

• IT Support;

• Legal and Professional Advisers;

• Marketing Advisors;

• Conference Venues;

• Sage – An accounting system;

• Tracker-RMS – A CRM system we use to securely manage our data;

• Office365 – An email and productivity system;

• Optimum Finance – A bespoke invoice finance solution business for SMEs;

• Odro – Video Technology Platform;

• Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us.

6. Special (or Sensitive) Personal Data

Where we collect any special (or sensitive) personal information – examples include; race, ethnic origin, politics, religion, trade union membership, health, sex life, or sexual orientation - we will ask for your explicit consent. This includes any information regarding criminal convictions.

7. Marketing

If you provide your explicit consent to receive marketing we may send you:

• Information about our services

• Industry news about assessments for recruitment or employee performance

• Insights into creating assessments

You can remove your consent to marketing by contacting dp@phoenixhcm.co.uk

8. Cookies

We use cookies on our website to help improve your experience.

A cookie is a small text file that is downloaded on to your computer when you visit a website. Cookies are used by many websites. You can find out more about cookies and how to disable them using your browser but visiting https://ico.org.uk/for-the-public/online/cookies/.

9.     Other websites

This privacy policy only applies to this website. Our website includes links to other websites, on visiting the link you should check their privacy policies.

10. Changes to our privacy policy

From time to time we will update our privacy policy on this page. This version was last updated on 30th July 2020.

11. Your Rights:

You can find the contact details for our Data Protection Officer below or email dp@phoenixhcm.co.uk

• Right to be Informed – you can request information about the categories of data we hold on you by downloading this form or contacting our Data Protection Officer.

• Right to Access – you can request a copy of the data we hold on you by downloading this form or contacting our Data Protection Officer.

• Right to Rectification – You can request we update/correct any information we hold.

• Right to Erasure – You can request we delete the information we hold. In some cases, we have a legal right to retain your data, if this is the case we will explain why.

• Right to Restrict Processing – You can request we stop processing your data but will continue to hold it.

• Right to Data Portability – You can request we transfer your data to a third party or data controller of your choice.

• Right to Object – You can request we stop processing your data in relation to a legitimate interest or marketing purposes.

• Rights related to automated decision making including profiling – You can object to use using automated software to process your data and make decisions.

• You can complain to the Information Commissioners Office by visiting https://ico.org.uk/concerns/. We are a registered member under number ZA785644.

We will respond to any of the above within 30 calendar days.

12. How to contact us:

If you have any questions please contact our data protection officer via dp@phoenixhcm.co.uk or by writing to:

Data Protection Officer

Phoenix 51 Limited

Building One

Chalfont Park

Gerrards Cross

SL9 0BG