In this Privacy Notice, the term “personal data” means information relating toyou that allows us to identify you either directly or in combination with otherinformation we hold. For instance, when you contact us by email, telephone orvia our website, we collect your personal data, including your name, postaladdress, telephone number and date of birth (where relevant).
Special categories of personal data
The UK GDPR defines special categories of personal data as information about aperson's race and ethnicity, religious or philosophical beliefs, trade unionmemberships, political opinions, genetic data, biometric and health data, andinformation concerning a natural person's sex life or sexual orientation. Upscale Consultants Ltd does not collect special categories of personal data.
How do wecollect information from you?
Upscale Consultants Ltd. collects information about you when you visit ourwebsite and engage in any of the following activities:
a) search and browse for content;
b) subscribe to publications and reports;
c) register for online services;
d) join a mailing list;
e) participate in bulletin boards, discussion or messageforums;
f) submit data for a survey or quiz;
g) register for events and seminars;
h) submit resumes or work history information;
i) contact us for further information;
j) visit our website while logged into a social mediaplatform; or
Some pages on our website may permit you to send emails or other messages tous. Emails and messages sent to us will contain your name, email address, andany information you wish to include in the message.
So that you are fully aware of how and why we are using your data, it isimportant that you read this Privacy Notice and any other privacy notices thatwe may provide on specific occasions when we are collecting or processing yourpersonal data, such as when you provide us with your business card or othercontact information.
How we use your personal data?
We may use the information you provide to us for any of the purposes describedin this Privacy Notice or as stated at the point of collection (or as obviousfrom the context of collection), including:
- to administer and manage this website, including to confirm and authenticate your identity and prevent unauthorised access;
- to personalise and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you;
- to sort and analyse user data (such as determining how many users from the same organisation have subscribed to or are using this website or Moore UK services);
- to determine the company, organisation, institution, or agency that you work for or with which you are otherwise associated;
- to develop our business and services;
- to conduct benchmarking and data analysis, including, for example, regarding usage of this website and demographics analyses of their users;
- to conduct quality and risk management reviews;
- to understand how people use the features and functions of this website in order to improve the user experience;
- to monitor and enforce compliance with our business terms, including acceptable use policies, legal and other regulatory obligations to which Upscale Consultants Ltd. is subject; and/or
- any other purposes for which you provided the information to Upscale Consultants Ltd., including any of the purposes given in the ‘Purpose of this privacy notice’ section above.
We do not share or sell your personal information to third parties formarketing purposes. The only time we may disclose your personal data to athird-party is when we are legally required to do so, or we are required to doso by our regulators.
What lawful bases do we use to process your information?
The lawful bases for processing personal data are set out in Article 6 of theUK GDPR.
At least one of these must apply whenever personal data is to be processed:
a) Consent: you have given your consent for Upscale ConsultantsLtd. to process your personal data for a specific purpose.
b) Performance of a contract: the processing is necessary forthe performance of a contract that you have with Upscale Consultants Ltd.,including for the purposes of entering a contract Upscale Consultants Ltd.
c) Compliance with legal obligation: the processing by Upscale ConsultantsLtd. is necessary to comply with the law (e.g. the tax/social securityobligation/employment law) (not including contractual obligations).
d) Vital interests: the processing is in yours, or someoneelse’s vital interests.
e) Public interest: the processing is necessary to enable UpscaleConsultants Ltd to perform a task in the public interest or an officialfunction, and the task or function has a clear basis in law.
f) Legitimate interests: the processing is necessary in yourlegitimate interests or the legitimate interests of Moore UK, or those of athird-party, unless the need to protect your personal data overrides thoselegitimate interests.
With whom do we share your personal data?
Upscale Consultants Ltd. may disclose your information to third parties if weare under a duty to disclose or share your personal data in order to complywith any legal obligation, or in order to enforce or apply any agreements, orto protect the rights, property, or safety of the organisation, or otherindividuals. Such disclosures include, but are not limited to, exchanginginformation with other companies and organisations for the purposes ofsafeguarding or other statutory regulations that Upscale Consultants Ltd. hasto comply with as well as those organisations with whom you and UpscaleConsultants Ltd. havereciprocal agreements for providing services i.e. education, professionaldevelopment etc.
How longwill we hold your personal data?
Upscale Consultants Ltd will retain your personal data in a live environmentfor as long as necessary to fulfil the purpose(s) for which it was collected(including as required by applicable law or regulation, typically 7+ years).
We may keep your data for longer to establish, exercise, or defend our legalrights and yours. Where such a need exists, your personal data will be securelyarchived with restricted access and appropriate safeguards applied to ensurethe security and confidentiality of your information.
Upscale Consultants Ltd. is required tokeep details of financial transactions for seven years to meet accountancy andHMRC requirements. We will anonymise or delete personal data if, after a periodof seven years, we have not had any contact or communication from you (thiswill be measured on a rolling seven-year period).
We maintain a data retention criterion to help implement our record retentionand disposal (RR&D) requirements. Our RR&D Schedule takes account ofour legal and accounting obligations, balancing this with what would beconsider to reasonable.
We may anonymise your personal data (so that you can no longer be identified)for historical research and analysis without further notice to you.
Securityof your personal data
Upscale Consultants Ltd. respects the privacy of individuals and is committedto protecting your personal data. Accordingly, in accordance with the DataProtection Act 2018 and UK GDPR, we have implemented appropriate technical andorganisational measures to protect your personal data against unauthorised orunlawful processing and against accidental loss, destruction, or damage. Thesemeasures include having clear internal policies and procedures and maintainingthe physical security to our premises.
Your personal data will not be sold or disclosed (other than as specified underthis Privacy Notice) to another company or organisation.
Additionally, we put in place appropriate IT security technologies andprocedures to prevent the unauthorised access, damage, and loss of your dataand our access controls ensure the confidentiality of the data we process.
Please note that the transmission of information via the Internet is notcompletely secure, and while we do our best to protect your personal data, wecannot guarantee the security of any data sent to our site; such transmissionsare at your own risk.
Locations of Processing
The data we collect from you is processed on our servers located in the EU. Wewill ensure that your personal data is provided with adequate protection if itbecomes necessary to transfer your personal data to a country that has not beengranted a finding of adequacy by the European Commission (EC). Transfers ofpersonal data outside of the European Economic Area (EEA), to a country thathas not been granted a finding of adequacy by the EC, will be carried out using‘appropriate safeguards’ i.e. Binding Corporate Rules (BCR), Standard ContractClauses (SCC) (also known as Model Contract Clauses) or in accordance withapproved Codes of Conduct. Alternatively, we will seek your consent, on acase-by -case basis, where appropriate to do so.
Links to other websites
Our website contains links to other websites. The processing of personal datathrough those websites is not covered by this Privacy Notice, and we encourageyou to review the privacy notices / privacy policies on the third-party websiteto discover more about how they process your information.
What atare my data subject rights?
We support your data subject rights under the Data Protection Act 2018 and theUK GDPR, in relation to our processing of your information, including your:
- right to be informed (chiefly via this Privacy Notice)
- right of access
- right to rectification
- right to erasure
- right to restrict processing
- right to data portability
- right to object
- rights related to automated decision-making including profiling.
You can exercise these rights at any time, including your right to request acopy of the information we hold about you (otherwise referred to as a SubjectAccess Request (SAR), or by contacting us using any of the methods shown belowin the ‘How do I contact you?’ section.
We will respond to your request as quickly as possible: usually, this will bewithin one month of receiving your request.
Updatingmy information
You may choose to correct, update, or delete your personal data by contactingus using any of the methods shown below in the ‘Make an enquiry/Contact us’section.
If you have opted-in to receiving communications form us, your preferences willremain in effect until you tell us that you want to opt-out of receiving anyfurther communications.
You can change your mind at any time by clicking the link on the communicationswe send you or by contacting using any of the methods shown below in the ‘Makean enquiry/Contact us’ section. If you choose to unsubscribe from any orall mailings, we may retain information sufficient to identify you so that wecan honour your request.
Withdrawing my consent
Where we process your information based on your consent, you may withdraw yourconsent at any time. You can do this by contacting us using any of the methodsshown below in the ‘Make an enquiry/Contact us’ section.
Making a complaint to us
We hope you’ll never have need to do so, but if you do want to complain aboutour use of your information or our facilitation of your data subject rights,you can contact us using any of the methods shown below in the ‘Make anenquiry/Contact us’ section.
Our DataProtection Officer will investigate your complaint and provide you with anappropriate response as quickly as possible.
Making a complaint to the Information Commissioner
You can, of course, lodge a complaint with the Information Commissioner at anytime. For instance, if you are unhappy with the way in which we are processingyour information, or we have failed to facilitate your data subject rights.
Further information about your data subject rights and how to complain to theICO can be found here: ICO Make a Complaint
How do I contact you?
You may contact us using any of the following methods:
By post:
Data Protection Officer
Upscale Consultants
170 Kennington Lane
London, SE11 5DP
By email: marketing@weupscale.com
Changes to this Privacy Notice
We continuously review the content of our Privacy Notice to ensure that itscontent accurately reflects what we are doing with your information.