The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation, the data controller is Capium Limited of 3rd Floor 86-90 Paul Street, London, England, EC2A 4NE.
Our DPO is Michael Blakeley, who is a qualified DPO and can be contacted on Michael.firstname.lastname@example.org
Who we are and what we do
We are an accounting software provider who We may also from time to time provide services such as training and support services. We collect personal data of the following types of people to allow us to undertake our business;
- You our customer and your employees we interact with;
- Your customers data which you share with us to help us to provide you with our services;
- Supplier contacts to support our services;
- Our own Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms or registering on our site www.capium.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) and how you interact with our site.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary, independent contract or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
We have a number of lawful reasons that mean we can use your personal information, including your consent, where you give it. One lawful reason is something called ‘legitimate interests’. In general terms, “Legitimate Interests” means we can process your personal information if:
- We have a genuine and legitimate reason; and
- We are not harming any of your rights and interests.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.
Disclosure of your information inside and outside of the EEA
There are certain third parties we work with to help us to delivery to you the best service we can. In order to achieve this we will share your personal information with:
- Microsoft Azure, our hosting partner. We use Microsoft Azure, a top tier data hosting service, to host our service.
- We use Yodlee (www.yodlee.com) to provide a service that lets you add details of the accounts which you want to use in connection with the Capium service. When you add an account Yodlee collects and stores your log in details, such as user name and password. This information is never stored by us nor subsequently disclosed to us and is subject to Yodlee’s policy on how Yodlee keeps your information secure please visit http://yodlee.com/yodlee-security/. Yodlee are headquartered in the USA]. Yodlee may: (a) use customer data internally to provide and improve its services; (b) to the extent permitted by law, use, sell, license, distribute and disclose aggregated data which does not identify any individual person; and (c) perform fraud screening, verify identities, and verify the information contained in bank accounts for use across the Yodlee network. Yodlee will not disclose any customer data to any third party other than aggregated data.
- Companies House, HMRC, your financial institution, and other entities we may contact on your behalf, in respect of which you may give us your authentication credentials (such as user name and password).
- Hubspot, the third party customer relationship management tool we use. Hubspot gives us the ability to personalise some content for different user groups. If you sign up for our blog or any other notification we will store your details securely in our Hubspot account. Hubspot is a US company which has certified under the EU-US Privacy Shield framework.
- Our support team in India who may be used to address any support queries you raise. Our Indian team has agreed to standard data protection obligations prescribed by the European Union to ensure that your data is held in accordance with EU data protection standards.
- Gocardless, to set up payment mandates. For details on Gocardless privacy practices, see https://gocardless.com/legal/privacy/.
- Mailchimp, our email campaign service provider, to keep you up to date with Capium news. Mailchimp has certified its agreement to the EU/US Privacy Shield.
- business partners, suppliers and sub-contractors for the provision of the Capium service to you.
- analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Capium Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the provision of accountancy services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our accountancy services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
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 delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing
of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
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 in certain formats, if practicable.
Make a complaint
to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
A subject access request should be submitted to our Data Protection Officer Michael.email@example.com No fee will apply as laid down by the GDPR.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
We hope that we have shared with you all the information you need, but in the event that we haven’t, or if you have any questions then please do not hesitate to contact our Data Protection Officer Michael.firstname.lastname@example.org