The last update to our Privacy Policy was posted on May 2018. This document governs the Privacy Policy of www.octopusgrp.com.

About this Notice

For all of us at Octopus Communications Consultancy Limited (“Octopus”, “we” or “us”), the protection of personal data is of paramount importance and we go to great lengths to ensure that we collect and use personal data lawfully and only for specific purposes.

This Notice applies to personal data which we process about [job applicants and past employees, personnel of customers, suppliers, partners and other organisations who we work with as part of our business operations, visitors to our website and users of our products and services] (each of which we refer to in this Notice as “data subject” or “you”).

In this Notice we explain the things which we think are important for you to know about the personal data we collect from you such as who we are, how we use your data, how we protect your data and who we may share your data with. We also explain the rights you have in relation to your personal data which we hold. Finally, there’s a bit about cookies – what they are and how to get rid of them if you don’t want them. If you have any questions relating to how we handle your personal data, please write or email us at the contact address set out below.

This Notice does not cover the links within our website linking to other websites. We encourage you to read the privacy statements of the other websites you visit. 

About us

Octopus is a limited company established in England with company registration number 03842600. Our registered and business address is at 222 Grays Inn Road, London, WC1X 8HB .

We are a data controller in relation to your personal data because we decide what your personal data can be used for and how the personal data is processed.

Where we process personal data on behalf of another company or organisation, we will be doing so as a data processor and our processing will be governed by a contract which we will have with the data controller who will have a separate privacy notice which will apply.

If you would like to contact us in relation to this Notice or your personal data, please contact our Data Protection Manager via email at dataprotectionmanager@octopusgrp.com or by post to the following address:

 

Data Protections Manager

Octopus Communications Consultancy Limited

7th Floor, 222 Grays Inn Road,

London, WC1X 8HB

 

About your personal data

 

The personal data we collect, the purpose(s) we use it for and the lawful basis we hold it will vary depending on the category of the person it relates to. To help explain this, we have set out these separate categories as follows:

 

EMPLOYEES, WORKERS, DIRECTORS AND CONTRACTORS

What is the purpose of this document?

Octopus Communications Consultancy Limited (Octopus Group) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

It applies to all employees, workers, directors, and contractors.

 

Octopus Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers, directors, and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

 

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

 

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

 

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Gender.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave, pension, and benefits information.
  • Start date.
  • Location of employment or workplace.
  • Copy of driving licence.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage and other information obtained through electronic means such as swipe card records
  • Information about your use of our information and communications systems.
  • Photographs

We may also collect, store, and use the following “special categories” of more sensitive personal information:

  • Information about your health, including any medical condition, health, and sickness records.

How is your personal information collected?

We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest or for official purposes.

 

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the UK.
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions.
  • Providing you with the following benefits:
    • Private Medical Insurance
    • Health Cash Plan
    • Payroll and online payslips
    • Childcare Vouchers
    • Perkbox
    • Life Assurance
    • Free eye tests
  • Liaising with your pension provider
  • Administering the contract, we have entered into with you
  • Business management and planning, including accounting and auditing
  • Conducting performance reviews, managing performance, and determining performance requirements
  • Making decisions about salary reviews and compensation
  • Assessing qualifications for a particular job or task, including decisions about promotions
  • Gathering evidence for possible grievance or disciplinary hearings
  • Making decisions about your continued employment or engagement
  • Making arrangements for the termination of our working relationship
  • Education, training, and development requirements
  • Dealing with legal disputes involving you, or other employees, workers, and contractors, including accidents at work
  • Ascertaining your fitness to work
  • Managing sickness absence
  • Complying with health and safety obligations
  • To prevent fraud
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

 

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with employment.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about clients or former clients in the course of legitimate business activities with the appropriate safeguards.

 

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

 

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

 

We do not envisage that we will regularly hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences solely as part of any safeguarding and/or legally required verifications.  We are allowed to use your personal information in this way to carry out our legal obligations. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration.

2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.

3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

 

We may have to share your data with third parties, including third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

 

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: Finch (pension administration, benefits provision, and administration), Perkbox, Trace, Appraisd,  

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information 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 information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We do not envisage transferring the personal information we collect about you outside of the EU.

Data security

 

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will generally retain records for seven years after the end of your relationship with us to ensure that we have sufficient records in the event of any dispute as to our contractual, legal or tax obligations.  We shall retain your name, address, dates of employment and last job title, for a period of ten years to enable us to respond to reference requests from any future employer.  We will only be able to hold your information beyond these periods of time with your express, informed consent.  Once these periods of time have passed we will securely destroy your personal information.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • 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.

If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Head of Talent in writing.

No fee usually required

You will not have to pay a fee to access your personal information (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. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

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.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Head of Talent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection manager

We have appointed a Data Protection Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our Data Protection Manager. 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.

 

Customer Personnel

 

What personal data we collect

 

We may collect your personal data when you correspond with us on behalf of the company or organisation that you work for.

 

The personal data we collect will typically include your name, the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address.

 

How we use your personal data

 

We will use your personal data only to correspond with you in the course of business conducted between us and the organisation you work for or represent. This may include notifying you about existing products and services which we provide to your organisation or informing you about new products and services which we think your organisation may be interested in.

 

The lawful basis for our collection and use of the personal data

 

Our processing of this personal data is necessary for the purposes of our legitimate interests in carrying out business with the organisation which you work for or represent and to correspond with you.

 

Supplier Personnel

 

What personal data we collect

 

We may collect your personal data when you correspond with us on behalf of the company or organisation that you work for.

 

The personal data we collect will typically include your name, the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address.

 

How we use your personal data

 

We will use your personal data only to correspond with you in the course of business conducted between us and the organisation you work for or represent. This may include contacting you in connection with existing products and services which your organisation provides to us, for billing and payment and in response to your enquiries.

 

The lawful basis for our collection and use of the personal data

 

Our processing of this personal data is necessary for the purposes of our legitimate interests in carrying out business with the organisation which you work for or represent and to correspond with you.

 

Personnel from prospective customers

 

What personal data we collect

 

We may collect your personal data in connection with marketing events, sales opportunities or in response to requests for information which you have made to us.

 

The personal data we collect will typically include your name, the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address.

 

How we use your personal data

 

We will use your personal data only to correspond with you in connection with our provision of products and/or services to the organisation you work for or represent.

 

The lawful basis for our collection and use of the personal data

 

Our processing of this personal data is necessary for the purposes of our legitimate interests in offering products and/or services to the organisation which you work for or represent and to correspond with you.

 

Users of our products and/or services

 

What personal data we collect

 

We may collect your personal data in connection your purchase or use of our products and/or services. You may also provide your personal data to us when you visit our website (for example by creating an account with us) and when you communicate with us.

 

The personal data we collect will typically include your name, the name and address of the company you work for, your business telephone number, your mobile telephone number and your email address.

 

How we use your personal data

 

We will use your personal data only for the purpose of providing to you our products and/or services, to improve our products/services, to provide customer service and support to you and as part of our collection of customer feedback, where applicable for billing and payment purposes and in response to your enquiries.

 

The lawful basis for our collection and use of the personal data

 

Our processing of this personal data is necessary for the purposes of our legitimate interests in providing our products and/or services to you. Our processing is also necessary for us to comply with a legal obligation to which we are subject, to maintain appropriate business records, to comply with lawful requests by courts and regulatory authorities and for us to comply with applicable laws and regulations. [Our processing of your personal data is also necessary for the performance of our contract with you in relation to our products/services]

 

Visitors to our website

 

What personal data we collect

 

When you visit our website, we may collect your personal information where you submit a form containing your personal data or where the website helps you send an email to us.

 

Information we collect

 

We collect personal information when you register to request information about our services or otherwise provide such information.

 

This information includes the following categories:

 

  • Personal Contact Information
  • Topics of interest
  • Industry Information
  • Company Information

 

Generally, you control the amount and type of information you provide to us when using our Website. As a visitor to our Website, you can browse our Website to find out more about us. You are not required to provide us with any PII as a Visitor.

You may decline to provide PII to us in our forms and/or refuse cookies in your browser, although some of our features or services may not function properly as a result. We make good faith efforts to provide you access to your personal information upon request and to let you correct such data if it is inaccurate and delete it, when reasonably possible.

 

Computer information collected

 

When you use our Website, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information is typically considered NPI. We may also collect any of the following:

  • Cookies
    Our Website uses “Cookies.” A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to identify the areas of our Website that you have visited. We also use cookies and other technologies to enhance your online experience by eliminating the need to register multiple times for registration-required content. Finally, we may use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies (see below). However, if you disable Cookies, you may not be able to access features on our Website correctly or at all. We never place PII in Cookies.
  • Automatic Information
    In the interest of providing our visitors and customers with a secure online experience, our servers automatically record information when you visit our website, including the URL, IP address, browser type and language, and the date and time of your request. We use all of this information to analyze trends among our users to help improve our Website.
  • Google Analytics Privacy Policy
    Our website uses “Google Analytics” to collect information about the use of our site. Google Analytics collects information such as how often users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to our site. We use the information we get from Google Analytics to improve our site. Google Analytics collects only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use. https://www.google.com/analytics/terms/us.html You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. https://tools.google.com/dlpage/gaoptout

 

 

How we use your personal data

 

We will use your personal data only for the purpose of communicating with you in response to your enquiries.

 

The lawful basis for our collection and use of the personal data

 

Our processing of this personal data is necessary for the purposes of our legitimate interests in providing our products and/or services to you.

 

Our safekeeping of your data

 

We will periodically evaluate your personal data which we hold to determine whether we should continue to hold it. We have implemented all appropriate technical, organisational and security procedures to protect your personal data from unauthorised access or from accidental loss or corruption. These measures include restricting physical access to our premises where personal data is held and using access controls and firewalls to prevent unauthorised access to our systems. We recommend that you also take steps to safeguard your personal data against the risk of unauthorised access or accidental loss or corruption by backing up your personal data. Where we provide you with password-restricted access to our website, software and/or services, it is your responsibility to use a strong password and to keep it private.

 

Who we may disclose your personal data to

 

Except as set out above and save for the following exceptions, we will not disclose your personal information to any third party.

 

  • We may disclose your personal data to our group companies.
  • We will disclose your personal data to law enforcement agencies or regulatory bodies if we are required to do so by law.
  • We may disclose your personal details to a third party in connection with the sale or merger of our business.
  • We may employ other companies to provide services for us, including for example, processing of payments and freight which services are necessary in order for us to be able to provide our services to you. These companies have access to the personal information needed to perform their functions and not for any other purposes and are bound by confidentiality agreements not to disclose any information for any other purpose.

 

If at any time we wish to disclose your personal data in circumstances other than those above, we will always obtain your express consent before doing so.

 

We store your personal details on our servers in the United Kingdom and we will not be transferring your data outside the European Union.

 

How long we keep your personal data

Unless we provide for a specific duration in the categories set out above, we will keep your personal data for as long as is necessary for the purposes set out in this Notice after which time we will either delete your personal data or remove all personal identifiers from the data so that it has become anonymous.

 

International data transfers

 

We do not transfer your personal data to any country outside the EU.

 

Your rights in relation to your personal data

 

As a data subject, the law provides you with certain rights in relation to your personal data which we hold. You have the right to request the following: (1) Access to your personal data and information about why we hold it and who we can disclose it to; (2) Correction of your personal data if it is inaccurate, incomplete or out of date; (3) Deletion of your personal data (for example where you withdraw consent to our processing of your personal data or if you object to our processing and we have no overriding legitimate interest to continue to process your data); (4) Stopping the processing of your personal data for certain purposes such as direct marketing; (5) To receive your personal data in a commonly used machine-readable format or have this data sent to your designated recipient; and (6) To object to automatic decision making and profiling based on your personal data. Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.

 

To request a copy of your personal data or to make any other request outlined above, please contact our Data Protection Manager by email or by post at the contact details given at the start of this Notice. To safeguard the personal data we hold, we need to confirm your identity before we can take action following a request made under this section.

 

Contacting the Regulator

 

If you are not happy with how we have processed your personal data or how we have responded to a request you have made to us, you have the right to make a complaint to the Information Commissioner’s Office who is charged with regulating data protection and use of personal data. The Information Commissioner’s Office can be contacted through their website (www.ico.gov.uk) or by telephone (0303 123 1113).

 

Revisions to this Privacy Notice

 

We may change this Notice from time to time. If we make any material changes we will endeavour to place a notice on our website in advance of the changes. This Notice was last updated on 22nd May 2018.

 

 

Hello
We'd love to hear from you