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Privacy Policy

POLICY STATEMENT

Arcus Consultancy Services Limited (“the Company”) must gather and process certain personal information about individuals in the course of business.  It is important that this information is handled lawfully and appropriately in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’).

The Company takes our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.

 

WHAT IS PERSONAL DATA?

Personal data means data (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data (or from that data and other information in our possession).

Processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

Sensitive personal data includes personal data about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, physical or mental health condition, sexual orientation or sexual life. It can also include data about criminal offences or convictions.  Sensitive personal data can only be processed under strict conditions, including with the consent of the individual.

 

DATA PROTECTION PRINCIPLES

Anyone processing personal data, must ensure that data is:

The Data Protection Requirements are intended to ensure that it is done fairly and without adversely affecting the rights of the individual.   In accordance with the Data Protection Requirements, the Company will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.

 

NOTIFYING INDIVIDUALS

If we collect personal data directly from an individual, the Company will inform them about:

If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible (in addition to telling them about the categories of personal data concerned).

 

ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING

The Company will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.

 

ACCURATE DATA

The Company will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

 

TIMELY PROCESSING

The Company will not keep personal data longer than is necessary for the purpose or purposes for which it was collected.  We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.

 

PROCESSING IN LINE WITH DATA SUBJECT’S RIGHTS

The Company will process all personal data in line with data subjects’ rights, in particular their

right to:

 

TRANSFERRING PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

The Company may transfer any personal data we hold to a country outside the EEA or to an international organisation, provided that one of the following conditions applies:

Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.

 

SUBJECT ACCESS REQUESTS

All individuals whose data is held by the Company are entitled to:

If an individual requests the above information, this is called a subject access request. Subject access requests should be made by email to the Finance Director or another member of the OMT. The Finance Director will aim to provide the relevant data within one calendar month.

 

BREACH OF DATA PROTECTION

If personal data is accessed by unauthorised persons, the data breach must be reported immediately to the Finance Director or a member of the OMT in his absence, who will ensure that any significant breaches are reported to the Information Commissioner’s Office within 72 hours. An example of a data breach would be sending an emailing containing personal data to the wrong email contact, or being infected with an electronic virus.

Breach of this policy may be dealt with in line with the Company Disciplinary Policy.  If it is considered that a criminal offence has occurred the police will also be notified.