Privacy POLICY

01 INTRODUCTION

Group ADP Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data which you provide to us, or which we obtain, when providing services to you, when you use one of our websites www.groupadp.com and  www.british.management, or when we deal with you in the course of our business.  This policy applies to personal data we hold relating to clients, suppliers, employees, marketing contacts and other third parties. Depending on who you are, and how you interact with us, only some aspects of this policy may apply to you.

References to Group ADP Limited refer to the   applicable entities of Group ADP, including ( but not limited to affiliates,   associates of Group ADP Limited, company registration number 09344076, with   the registered address at International House, 36-38 Cornhill, London EC3V   3NG

We may update the polict from time to time. You may get an update by visiting our website www.groupadp.com

02 IMPORTANT INFORMATION

Group ADP is the controller and responsible for   your personal data. We have appointed a data privacy manager 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 the data privacy manager using the   details set out below.

Privacy Manager

Group ADP Limited

International House

 36-38 Cornhill

London

EC3V 3NG

Telephone Number: 0207 117 25 37

Third-party links

Our websites 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 statements. When you leave our website, we encourage you to   read the privacy notice of every website you visit.

3. THE DATA WE COLLECT ABOUT   YOU

We collect, use, store and transfer the following   data:

(a) Identity and Contact Data

personal and identity   data, including your names, date of birth, email address, postal address,   telephone number(s), copies of passports and ID, national insurance number;

(b) Financial Data: including details transactions data of your business transactions, tax records, annual reports and accounts,   

(c) Employment Data: your employment history   and qualifications

(d) Profile Data: Passwords and login   details for online accounts with us

(e) Technical Data: information we collect   automatically when you visit our websites, including your IP address, how you   use our site and the pages you visit, browser details, and device details

(f)  Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences. 

4. HOW WE COLLECT YOUR DATA

 We collect your data from different sources:

(a) We collect all of the types data listed above   directly from you when you interact with us;

(b) We collect some personal data from third party   search providers, such as details about criminal convictions from Experian,   and some Financial Data from debt management and collection agencies.

(c) We collect data from publicly available sources,   and third party databases, such as newspapers, and business data repositories   such as Dunn & Bradstreet.

 (d) We carry out searches against government   sanctions lists, and if your details are on such lists, we will receive   personal information, including information about possible criminal   convictions or offences.

 (e) We collect Technical Data automatically when you   interact with our website, by using cookies and other similar technologies.

5. HOW WE USE YOUR PERSONAL   DATA

We will only use your personal data when the law   allows us to.

(a) We have set out below, 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.

(b) 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 using the details above 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 below.

Purposes 

(a) To register you as a user on one of our websites

(b) To provide services to you and carry out your   instructions in connection with our services.

(c) To leave a review or take a survey

(d) To   enable you to partake in a competition or complete a survey

(d) To administer and protect our business and our website   (including troubleshooting, data analysis, testing, system maintenance,   support, reporting and hosting of data)

(d) To make   suggestions and recommendations to you about goods or services that may be of   interest to you

(e) To invite you to networking and professional   events, and to inform you about developments in our business

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. In addition, we may process your personal data without your knowledge or consent, only when this is required or permitted by  law.

MARKETING

We may use your personal data to form a view on   what we think you may want or need, or what may be of interest to you. This   is how we decide which services and offers may be relevant for you. You will receive marketing communications from us   in respect of our business and our services if you have requested information   from us or purchased services from us and, in each case, you have not opted   out of receiving that marketing. We do not share your contact details with any   third party for the purpose of that third party sending marketing. You can ask us or third parties to stop sending   you marketing messages at any time by following the opt-out links on any   marketing message sent to you or by contacting use using the details above at   any time.

06. 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, 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 or disclosure   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.  We will usually keep your data for between 6   years and 10 years from inception of the last insurance policy that you   incepted with us. For full details of our retention periods, please contact   our data privacy manager.

07. YOUR LEGAL RIGHTS

(a) Under certain circumstances, you have rights   under data protection laws in relation to your personal data. These rights   are set out below.  If you wish to exercise any of the rights set out   above, please contact our Data Privacy Manager.

(b) 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.

(c) Complaint to the ICO

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.

Other Rights

(a) 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.

(b) Request correction of the personal data that   we hold about you. This enables you to have any incomplete or inaccurate data   we hold about you corrected.

(c) 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.

(d) 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.

(d) 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: (i) if you want us to   establish the data's accuracy; (ii) where our use of the data is unlawful but   you do not want us to erase it; (iii) 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 (iv) you have objected to our use of your data but we need to   verify whether we have overriding legitimate grounds to use it.

(e) 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. 

(f) 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.