PRIVACY NOTICE

1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time.

Our practices regarding your personal data and how we will treat it are described below.

2. ABOUT US

Aquarius Project Associates hereinafter ('we', 'us', 'our' and 'ours') is a  consultancy trading from 100 Pall Mall, St James SW1Y 5NQ London and  with registered address at Pickhill Business Centre, Smallhythe Road, Tenterden, Kent TN30 7LZ and e-mail: office@aquariusprojects.com

For the purpose of the Data Protection Legislation and this notice, we are the 'data controller'. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

We have appointed Data Protection Officers. Our Data Protection Officers are our Data Protection Points of Contact and are responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Points of Contact you can do so using the contact details noted at paragraph 13 (Contact Us),  as noted.

3. HOW WE MAY COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

  • you provide a CV for employment or acting as a service provide to us; 
  • your details are within an appointment contract
  • you are employed or contracted with us
  • you contact us by email, telephone, post (for example when you have a query about our services or potential employment); or 
  • personal data is obtained  from third parties and/or publicly available resources for reference material.

4. THE KIND OF INFORMATION WE HOLD ABOUT YOU

The information we hold about you may include (but not limited to) the following:

  • your personal details (such as  nut not limited to your name, address, date of birth and passport, identity card, driving licence  numbers);
  • details of contact we have had with you in relation to the provision, or the proposed provision, of  services;
  • details of any services you have provided with us;
  • our correspondence and communications with you;
  • information about any complaints and enquiries you make to us;
  • Information we receive from other sources, such as publicly available information, information provided by your current or past employer.
  • Any annual medical tests as required by labour law.

5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU

We may process your personal data for purposes necessary for the performance of our contract with you, or our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal data

We may use your personal data in order to:

  • carry out our obligations arising from any agreements entered into between you,  our clients and us (which will most usually be for the provision of our services);
  • carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a sub-consultant or supplier or customer of our client; 
  • provide you with information related to our services which we feel may interest you; 
  • notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

Data Retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

  • the requirements of our business and the services provided;
  • any statutory or legal obligations;
  • the purposes for which we originally collected the personal data;
  • the lawful grounds on which we based our processing;
  • the types of personal data we have collected;
  • the amount and categories of your personal data; and
  • whether the purpose of the processing could reasonably be fulfilled by other means.

The following provides guidance on the retention periods relating to different types of data:

Existing Clients and Suppliers

We will retain data pertaining to contact details and past performance indefinitely. Please note that our accounting and tax software does not enable us to remove data relating to specific tax years and therefore, data held on our software will remain until we are able to remove the data subject in its entirety in accordance with full  legal requirements.

Former Clients and Suppliers

We will retain data pertaining to tax and accounting records for a period of ten years following the end of the tax year to which the information relates. This can include, but is not limited to, invoices, credit notes, payroll information, bookkeeping records, income details and tax payments.

The process of reviewing our records for those ready for destruction will only be carried out once a year. Therefore, for the period immediately following the termination of our services, we will therefore still hold some data for longer than ten years.

Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

6. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

"Third parties" includes third-party service providers. The following activities are carried out by third-party service providers: IT services, professional advisory services, auditors and assessors from our regulatory bodies, administration services, and banking services.

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We will only transfer the personal data we collect about you outside of the EEA when it is necessary by law or as a result of proposal where you have provided specific prior consent to participation.

8. DATA SECURITY

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

To maintain security of the website we have a strict password allocation policy and any enquiries that come via the website are sent by email. These emails are directed to the partners and the user accepts that by using the enquiry facility they are consenting for their contact details to be submitted and stored.

We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

  • Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
  • Request correction of the personal data that we hold about you. 
  • 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 exercised your right to object to processing (see below).
  • 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 basis. 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 data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

If you want to exercise any of the above rights, please email our data protection point of contact office@aquarius projects.com

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact as noted above.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. LINKS TO OTHER WEBSITES

Our website contains links to other websites. This Privacy Notice applies only to this website so when you access links to other websites you should read their own privacy policies.

12. CHANGES TO THIS NOTICE

Any changes we may make to our privacy notice in the future will be updated on our website at: 

www.aquariusprojects.com

This privacy notice was last updated on 15th May 2018.

13. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point , or contact them in writing at our registered address.

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the Romania supervisory authority for data protection issues, at any time. The ICO's contact details are as follows:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745

Website - https://ico.org.uk/concerns

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