Privacy Policy

Columna Protection® Limited (”We”) are committed to protecting and respecting your privacy.

Any mention of “Our Group” means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).

This notice together with our terms of business sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is 64 Yardley Green Road, Birmingham, England, B9 5QE

We collect information about you to carry out our core business and ancillary activities.We record all incoming and outgoing calls handled by Columna Protection® Ltd for a maximum of 6 months.

Information you give to us or we collect about you

This is information about you that you give us by filling in forms on our site  (available on request) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Information we collect about you when you visit our website

With regard to each of your visits to our site we will automatically collect the following information:

• technical information, including      the Internet protocol (IP) address used to connect your computer to the      Internet, your login information if applicable, browser type and version,      operating system and platform;
• information about your visit,      including the full Uniform Resource Locators (URL), clickstream to,      through and from our site (including date and time), products you viewed      or searched for’ page response times, download errors, length of visits to      certain pages, page interaction information (such as scrolling, clicks,      and mouse-overs), methods used to browse away from the page and any phone      number used to call our company telephone number.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

• to carry out our obligations      arising from any contracts we intend to enter into or have entered into      between you and us and to provide you with the information, products and      services that you request from us or we think will be of interest to you      because it is relevant to your career or to your organisation.
• the core service we offer to our clients      to provide you with information about other goods and services we offer      that are similar to those that you have already purchased, been provided      with or enquired about.

Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on contractual obligations if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation in some cases, if we are legally required to hold information on to you to fulfil our legal obligations.

We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the legal basis for processing include permission to introduce you to a client (if you are a customer).

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses we will make of your data:

We will also use your data:

• To administer our site and for      internal operations, including troubleshooting, data analysis, testing,      research, statistical and survey purposes;
• To improve our site to ensure      that content is presented in the most effective manner for you when you      are using your computer or other devices;
• To notify you about changes to      our service;
• To allow you to participate in      interactive features of our service, when you choose to do so;
• As part of our efforts to keep      our site safe and secure;
• To measure or understand the      effectiveness of advertising we serve to you and others, and to deliver      relevant advertising to you;
• To make suggestions and      recommendations to you and other users of our site about goods or services      that may interest you or them

We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision making process.

Do you have to provide us with personal data?

You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Disclosure of your information inside and outside of the EEA

We will share your personal information with:

• Any member of our group both in      the EEA and outside of the EEA.
• Selected third parties including:
• clients, business partners,      suppliers and sub-contractors for the performance and compliance      obligations of any contract we enter into with them or you;
• subcontractors including email      marketing specialists, event organisers, payment and other financial      service providers
• analytics and search engine      providers that assist us in the improvement and optimisation of our site;
• credit reference agencies, our      insurance broker, compliance partners and other sub-contractors for the      purpose of assessing your suitability for a role where this is a condition      of us entering into a contract with you.

We will disclose your personal information to third parties:

• in the event that we sell or buy      any business or assets, in which case we will disclose your personal data      to the prospective seller or buyer of such business or assets.
• if Columna Protection®  Limited or substantially all of its      assets are acquired by a third party, in which case personal data held by      it about its customers will be one of the transferred assets.
• if we are under a duty to      disclose or share your personal data in order to comply with any legal      obligation, or in order to enforce or apply terms and conditions of supply      of services  and other agreements;      or to protect the rights, property, or safety of Columna Protection®  Limited, our customers, or others. This      includes exchanging information with other companies and organisations for      the purposes of fraud protection and credit risk reduction.

The lawful basis for the third party processing will include:

• their own legitimate business      interests in processing your personal data, in most cases to fulfil their      internal resourcing needs;
• satisfaction of their contractual      obligations to us as our data processor;
• for the purpose of a contract in      place or in contemplation;
• to fulfil their legal      obligations.

Where we store and process your personal data

The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

• Unfortunately, the transmission      of information via the internet is not completely secure. Although we will      do our best to protect your personal data, we cannot guarantee the      security of your data transmitted to our site; any transmission is at your      own risk.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

• We do the following to try to      ensure our data is accurate:
• our website enables you to manage      your data and to review whether the details we hold about you are accurate
• prior to making an introduction      we check that we have accurate information about you
• we keep in touch with you so you      can let us know of changes to your personal data

We segregate our data so that we keep different types of data for different time periods.The criteria we use to determine whether we should retain your personal data includes:

the nature of the personal data;

• its perceived accuracy;
• our legal obligations;
• whether an interview or placement      has been arranged; and
• our recruitment expertise and      knowledge of the industry by country, sector and job role.

We may store and handle your data in the following ways:

• We may archive part or all of      your personal data, retain it on our financial systems only or delete all      or part of the data from our main Customer Relationship Manager (CRM)      system.
• We may pseudonymise parts of your      data, particularly following a request for restriction or erasure of your      data, to ensure that we do not re-enter your personal data on to our      database, unless requested to do so.

Recorded telephone calls will be kept for a maximum of 6 months.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us at info@columna-protection.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The UK GDPR provides you with the following rights. To:

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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 ground. 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 information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party in certain formats, if practicable.

Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Access to information

The Data Protection Act 1998 and the GDPR Act give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with these Acts.

A subject access request should be submitted to info@columna-protection.com.No fee will apply.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Columna Protection® Ltd 64 Yardley Green Road, Birmingham, England, B9 5QE