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

• you request a proposal from us in respect of the services we provide
• you register as a candidate for UMBRA Select
• you or your employer or our client engages us to provide our services and also during the provision of those services
• you contact us in person, by email, telephone, post or social media (for example when you have a query about our services)
• we receive data from third parties and/or publicly available resources

The information we hold about you may include the following:

• your personal details (such as your name and/or address, phone numbers, email addresses)
• documentary data (such as passport, driver licence, records of electronic identity searches)
• information on your children. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
• information that is automatically collected (such as via cookies when you visit one of our websites)
• visual images collected via closed circuit television (CCTV) if you visit our offices
• video and sound recordings of Skype or other online meetings or calls
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services
• details of any services you have received from us
• our correspondence and communications with you
• information about any complaints and enquiries you make to us
• information from research, surveys, and marketing activities
• information we receive from other sources, such as publicly available information, information provided by your employer or our clients or third parties.

There may be occasional situations where the information we require is a special category of personal data under the legislation. In this case we will explain why we need it and obtain your consent to obtain and/or process the data.

We may process your personal data for purposes necessary for the performance of our contract with you or your employer 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 marketing, 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.

We may use your personal data in order to:

• carry out our obligations arising from any agreements entered into between you or your employer or 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 subcontractor, supplier or customer of our client.
• provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes (you may opt out at any time from these communications by clicking the unsubscribe link at the bottom of any email).
• seek your thoughts and opinions on the services we provide.
• 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.

We will keep your personal information while you are a client or as long as required to meet our legal or regulatory obligations. We may keep it longer if we cannot delete it for legal, regulatory or technical reasons.

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
• whether the purpose of the processing could reasonably be fulfilled by other means.

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.

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.

“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT and cloud services, provision of staff and resources, professional advisory services, quality control reviews, insurance services, administration services, marketing 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.

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 other authority or to otherwise comply with the law.

The majority of your information is processed in the UK and EEA. However, as part of our services offered to you, some of your information may be transferred to countries outside of the EEA.

Where your information is being processed outside of the EEA we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice. We will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations. If you use our services whilst outside of the EU, your information may be transferred outside the EU in order to use out services.

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.

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.

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 letting your usual UIG contact know or 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.

This is a brief summary of your rights and there may be restrictions on some of them. If you wish to explore any of these rights at any time please contacting us using the contact details included below.

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.

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. We try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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 (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us as shown below, or, in relation to receipt of emails, you may click unsubscribe at the bottom of any marketing or general information email we send to you.

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.

We may collect information about your visits to our websites such as IP address, location, browser type, referral source, length of visit and number of page views. This information may be used to improve our websites’ usability and for marketing purposes. Personal data submitted on our websites could be used for the purposes specified in this privacy policy or in any relevant parts of the websites.

Cookies are used on our websites. A cookie is a text file sent by a web server to a web browser and stored in the browser. The file is then sent back to the server each time the browser requests a page form the server. This enables the web server to identify and track the web browser.

We may send a cookie which may be stored by your browser on your computer’s hard drive. The information we obtain from the cookie could be used to improve the website’s usability and for marketing purposes. We may also use that information to recognise your computer when you visit our website, and to personalise our websites for you. Browsers usually will allow you to refuse cookies but this could have a negative impact on the usability of many websites.

For further information please see our Cookie Policy, or visit www.aboutcookies.org or www.allaboutcookies.org.

We may provide other companies with statistical information about our users; however, this information will not be used to identify an individual user.

We will not provide any personal information obtained from your website visits to a third party unless you have given your permission.

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit