Action Planning (“AP”) understands that your privacy is important to you and that you care about how your personal data is collected, stored and used. AP respects and values the privacy of everyone whose data we hold including our clients, those we interact with in the course of our work and visitors to this website, www.actionplanning.co.uk (“AP’s Site”). AP will only collect and use personal data in the ways that are described in this Policy and in a manner that is consistent with AP’s obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“personal data” refers to any and all data that relates to an identifiable person who can be directly or indirectly identified from that data and in this Policy, specifically means any personal data that AP collects, stores or processes in delivering its products or services or otherwise in the course of running its business.
“AP” or “Action Planning” (and also “we”, “our” or “us”) means Action Planning Consultancy Ltd, a limited company (05524544) whose registered office is at 99 Ashurst Road, Tadworth, England, KT20 5EY.
This Policy shall, where and so far as applicable, incorporate the definitions provided in the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (“GDPR”).
2. Information About AP
2.1 AP’s Site is owned and operated by Action Planning.
2.2 AP’s Data Protection Officer is David Saint, who can be contacted by email at firstname.lastname@example.org, by telephone on 01737 814758, or by post at 99 Ashurst Road, Tadworth, Surrey, KT20 5EY.
3. What Does This Policy Cover?
This Policy also covers your use of AP’s Site. AP’s Site may contain links to other websites. Please note that AP has no control over how your data is collected, stored, or used by other websites and AP advises you to check the privacy policies of any such websites before providing any data to them.
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and AP’s use of personal data have been designed to uphold:
4.1.1 The right to be informed about AP’s collection and use of personal data;
4.1.2 The right of access to the personal data AP holds about you (see section 12);
4.1.3 The right to rectification if any personal data AP holds about you is inaccurate or incomplete (please contact AP using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask AP to delete any personal data AP holds about you (AP only holds your personal data for a limited time, as explained in section 6.5 but if you would like AP to delete it sooner, please contact AP using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to AP using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about AP’s use of your personal data, please contact AP using the details provided in section 14 and AP will do its best to solve the problem for you. If AP is unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Does AP Collect?
The personal data which AP may collect will vary depending on the nature of your interaction with AP but might include some or all of the following personal and non-personal data:
5.1 your name;
5.2 the name of the charity/ business that you work for or represent;
5.3 the sector or cause in which your organisation operates, including any faith basis for that organisation;
5.4 your job title and/or profession;
5.6 your contact information such as email, postal address and telephone numbers;
5.7 demographic information about you, such as post code, preferences, and interests;
5.8 (in the case of users of AP’s Site) your IP address, web browser type and version and details of your operating system.
Specifically when running a recruitment campaign for a client, AP might be required to process special categories of data about you, such as information about your ethnic origin, sexual orientation or religion/ belief. In some cases information might also be required in respect of any criminal convictions and offences. Such information may be necessary where a client has an occupational requirement in respect of the role, to facilitate reasonable adjustments for candidates with a disability or to monitor recruitment statistics. In addition, information might also be required in respect of your current salary and benefits. Where such data is requested, it is because it is necessary for the fulfilment of obligations and/or the exercise specific rights in relation to the recruitment process and/or subsequent employment.
6. How Does AP Use Your Data?
6.1 All personal data shall be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. AP will comply with its obligations and safeguard your rights under the Data Protection Act 2018 and/or GDPR at all times. For more details on security see section 7, below.
6.2 AP’s use of your personal data will always have a lawful basis, either because it is necessary for AP’s performance of a contract with you, because you have consented to AP’s use of your personal data (e.g. by subscribing to emails), or because it is in AP’s legitimate interests. Specifically, AP may (without limitation) use your data for the following purposes:
6.2.1 Supplying AP’s products and/or services to you (please note that AP requires your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring AP’s products and/or services for you;
6.2.3 Delivering services to a third party which requires the processing of your data, for example where AP is undertaking a recruitment campaign for a client;
6.2.4 Replying to emails from you;
6.2.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing email@example.com or clicking on the unsubscribe link within the email);
6.2.6 Market research;
6.2.7 Reporting to third parties where products and/or services have been provided to you at their cost; and
6.2.8 Procuring services from you or working with you in the course of AP’s business.
6.3 With your permission and/or where permitted by law, AP may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news, and offers on AP’s products and services. AP will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that it fully protects your rights and complies with its obligations under the Data Protection Act 2018, the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. AP will provide ample opportunity to opt out of the receipt of any such marketing materials
6.4 You have the right to withdraw your consent to AP using your personal data at any time, and to request that AP deletes it.
6.5 AP does not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Where personal data about an AP client (or a provider of services to AP) has been obtained in order to deliver paid-for services, this may be retained for a period of up to 7 years following the end of the relevant contract;
6.5.2 Personal data in respect of third parties, obtained in the course of delivery of AP’s services shall be retained for up to 3 years;
6.5.3 All other personal data shall be retained for up to 3 years from the date on which the purpose(s) for which it was obtained cease to apply.
7. How and Where Does AP Store Your Data?
7.1 AP only keeps your personal data for as long as AP needs to in order to use it as described above in section 6, and/or for as long as AP has your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using AP’s services or AP’s Site or by otherwise submitting or providing information to AP. If AP does store data outside the EEA, AP will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Act 2018 and the GDPR.
7.3 AP has put in place 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.
7.3.1 AP has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Does AP Share Your Data?
8.1 Subject to the exceptions set out below (and/or elsewhere in this Policy) AP will not share any of your data with any third parties for any purposes, unless you have expressly given your consent for us to do so:
8.1.1 In certain circumstances, AP may be legally required to share certain data held by AP, which may include your personal data, for example, where AP is involved in legal proceedings, where AP is complying with legal obligations, a court order, or a governmental authority or where necessary to protect the rights, property, or safety of AP or others.
8.1.2 AP may sometimes contract with third parties to facilitate the effective operation of AP’s business and/or to supply services to you on AP’s behalf. These services may include payment processing, delivery of AP’s services, search engine facilities, email and other electronic communication tools, data back-up and other IT services, advertising, and marketing. In some cases, these services may include or require access to some or all of your data. In such circumstances, AP will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, AP’s obligations, and the obligations of the third party under the law.
8.1.3 In delivering its services, AP sometimes acts as the data processor for a client (which is the data controller), for example, where AP runs a recruitment campaign on behalf of a client and deals directly with job applicants. In such cases, your personal data may be shared with the data controller.
8.1.4 AP may compile statistics about the use of AP’s Site including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. AP may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.2 AP may sometimes use third party data processors that are located outside of the EEA. Where AP transfers any personal data outside the EEA, AP will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Act 2018 and the GDPR, including ensuring compliance with Privacy Shield requirements.
9. What Happens If AP’s Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you might not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 When you register for one of AP’s Services or submit personal data via AP’s Site, you may be given options to restrict AP’s use of your data. In particular, AP aims to give you strong controls on AP’s use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from AP which you may do by unsubscribing using the links provided in AP’s emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of AP’s Site without providing any data at all. However, to use all features and functions available, you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by AP (where such data is held). Under the GDPR, no fee is payable and AP will provide any and all information in response to your request free of charge. Please contact AP for more details at firstname.lastname@example.org, or using the contact details below in section 14.
14. Contacting AP