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This Policy applies to both personal information supplied to us either by an individual or by others. We may use personal information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.
This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference.
In this Policy, we use the terms:
“we”, “us”, and “our” (and other similar terms) to refer to: HCHR Limited which trades as Personology Our Company Registration number is 04369184
We will only process personal Information where we have a lawful reason for doing so. The lawful basis for processing Personal Information by us will be one of the following:
Personology may collect and process information about you from several sources which are outlined here.
In line with the expectations of the Data Protection Act (2018) and the GDPR regulations, we only collect necessary information that is required to allow us to promote and deliver our services fairly and effectively.
Under the Data Protection Act (2018) and European GDPR regulations, any person about whom organisations hold data (a ‘data subject’) is allowed to request a copy of that information. This is called a Subject Access Request (‘SAR’).
There is guidance for individuals who want to make a Subject Access Request on the website of the regulator, the Information Commissioners Office (‘ICO’) (https://ico.org.uk) and it is strongly recommended that you review this guidance before submitting your request to avoid any delays. There is also information on this site about requirements for SARs for both the requesting and responding parties, and who SARs should be sent to.
If you wish to make a subject access request to Personology, these should be submitted by email to email@example.com or by post to:
We collect and process information about you for several purposes depending on the context of the information and how it was collected:
If you provide your information to us through this website, we would consider this to mean you have a legitimate interest in our services, and that you are happy to be contacted in relation to those services, and that you are happy for us to share this with our relevant data sub-processors outlined below in order for our services to be delivered to you.
Personology must retain some information for periods in line with regulatory or legislative requirements. If there is no regulatory or legal requirement to retain your information, then it will be kept until one of the following is true:
If you believe any information held by Personology is incorrect and wish to amend it, please contact us in writing. Please see the section at the end of this Privacy Notice about how to contact us by email or post.
Personology does not wish to undertake marketing activity towards those who do not wish to receive it, and we will always comply with a request from you to either opt-out of marketing. We will comply with a request from you for your information to be erased if it is appropriate to do so (a) in accordance with the Data Protection Act (2018) or the European GDPR requirements and (b) if there is no legitimate justification for retaining the information.
In some cases, we may not be able to agree, wholly or in part, to your request for your information to be erased if there is a legitimate requirement to keep it. An example of a legitimate requirement would be if you are an employee of a company using Personology for outsourced HR services, and you are involved in some way with an HR issue which is being dealt with. In such a case, there is a legitimate requirement to retain relevant information relating to that issue in order for your employer to be able to resolve the HR issue and any related legal challenges. This may extend beyond the apparent resolution of the issue if there is a reasonable argument that the information may need to be revisited.
On occasion, we may need to share your Personal Information with third parties. We will only share Personal Information where we are legally permitted to do so.
Personology does not pass your information to third parties outside of Personology Network, other than to specific data sub-processors necessary for us to market and provide our services.
Where you supply us with Personal Information as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Information to third parties such as:
International transfers of Personal Information (including to outsourced service providers)
From time to time, we may need to transfer your Personal Information to organisations/individuals that are located in territories outside of the European Economic Area (“EEA”), in order to provide you with the services required.
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your Personal Information is only ever treated in accordance with this Policy.
Where necessary, we have entered into standard European Commission approved form model data protection clauses with parties that are located in territories outside of the EEA, to provide you with the service required and with our external service providers and business partners in relation to services that they may provide that involve processing data from locations outside of the EEA for which we are Data Controller.
We use Microsoft Office 365 to manage our emails and file storage, which may include some information that has been collected through our website or other sources relating to marketing and surveying activity. Microsoft have confirmed that they are DPA/GDPR compliant and have updated their terms and conditions to reflect this. Microsoft may transfer data outside of the EEA but will only do so in a manner which protects your data and meets the requirements of the GDPR and the Data Protection Act (2018).
Each of the sub-processors listed above may change and be updated at any time, but our commitment to the security of your data remains. Any new providers will be subject to the same vetting and selection process and will be governed by the same or similar terms and conditions.
Under these agreements, data may be transferred outside of the EEA but only where your rights and the rights of the data subject are protected and where that transfer is compliant with the requirements of the DPA and GDPR.
The information we collect is stored in secure cloud vaults that operate inside the EEA. This includes Mailchimp, Microsoft, Google & Act-On. All information is stored in an encrypted form. Information held by Microsoft on our behalf may be transferred outside of the EEA but only where there are appropriate protections in place and in line with GDPR guidance.
We have in place appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.
We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies using the following instructions, although in a few cases some of our website features may not function as a result. You can configure cookie settings in your browser’s settings.
Detailed step by step guidance on how to control and delete cookies is also available from www.aboutcookies.org.
We keep our Privacy Notice under regular review and we will place any updates on this web page.
If you would like to contact Personology in relation to any matter covered in this Privacy Notice or with queries about our website or marketing/survey activity, please email firstname.lastname@example.org or write to us at Personology
While we hope that you will not need to, if you want to complain about our use of Personal Information please send an email detailing your complaint to the Data Protection Officer.
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. The Information Commissioner can be contacted at:Information Commissioner’s Office