The Akenham Partnership - Privacy notice

The Akenham Partnership is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing personal data securely and transparently. This privacy notice sets out, in line with GDPR, how we will use your personal data. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

Who this notice applies to

This notice applies to current and former clients (and their employees), suppliers and third-party service providers.

Data controller details

The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: The Akenham Partnership, St Johns Innovation Centre, Cowley Road, Cambridge, CB4 0WS.

Data protection principles

In relation to your personal data, we will:

• process it fairly, lawfully and in a clear, transparent way
• collect your data only for reasons that we find proper for the performance of your contract
• only use it in the way that we have told you about
• ensure it is correct and up to date
• keep your data for only as long as we need it
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of data we process

The Company holds a range of information about you if you are a client (or employee of a client)

• your personal details including your name, address, date of birth, email address, phone numbers
• gender
• medical or health information including whether or not you have a disability
• current and previous job titles, job descriptions, pay grades, pension entitlement, hours of work and other terms and conditions relating to your employee’s employment
• letters of concern, formal warnings and other documentation with regard to any disciplinary proceedings
• performance information including measurements against targets, formal warnings and related documentation with regard to capability procedures, appraisal forms
• leave records including annual leave, family leave, sickness absence etc.
• training details
• psychometric profiles
• your Company bank account details

How we collect your data

We collect data directly from you at the beginning and throughout the duration of specific assignments, and during our ongoing business relationship.

In some cases, we will collect data about you from third parties, such as The Insights Group Ltd.

Personal data is kept in secure electronic files or within the Company’s systems.

Why we process your data

The law on data protection allows us to process your data for certain reasons only:

• in order to perform the contract that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• to protect your interests and
• where something is done in the public interest.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. We have set out below a description of all of the ways in which we plan to use your personal data.

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

Special categories of data

Special categories of data are data relating to your:

• health
• sex life
• sexual orientation
• race
• ethnic origin
• political opinion
• religion
• trade union membership
• genetic and biometric data.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

• you have given explicit consent to the processing
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
• you have already made the data public.

We will use your special category data:

• for the purposes of advising you or your employees on HR related matters

We may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Sharing your data

Your data may be shared with third parties where it is necessary for them to undertake their duties. This includes, for example, independent consultants and other partners from time to time. Where Akenham engages a consultant, they are provided with a company IT account and all personal data will be kept on Akenham’s secure systems.

We do not share your data with bodies outside of the European Economic Area.

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended.

Automated decision making

We will make some decisions about your employees based on automated decision making (where a decision is taken about you using an electronic system without human involvement). Predominantly, automated decision making will be carried out by our third-party providers. In most cases this will include psychometric assessments.

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• the right to portability. You may transfer the data that we hold on you for your own purposes
• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact us directly.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Making a complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.