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Indigogold Ltd – Privacy Policy

Indigogold Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when we deliver a service to you or when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

The ‘Controller’

Indigogold Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Email address: info@indigogold.com
Postal address: Indigogold, The Office Group, 201 Borough High St, London SE1 1GZ
Telephone number: +44 (0) 207 855 9606

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in February 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your data

In the course of delivering our service to you or through your use of our website, we may process and hold:

  • Your contact information, including name, address, email address and telephone number, either to register with us or for the purpose of receiving email notifications and our newsletter;
  • Information relating to any services we provide to you;
  • Details of your employment history and curriculum vitae (if you are a candidate seeking a placement with us or a client of ours);
  • Non-clinical psychometric information and other data collected in any assessment process you are involved in with us;
  • Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation behaviour – collected through the use of cookies and other tracking technologies);
  • Financial data, such your bank account details in order to process payments to you;
  • Any other information that you choose to provide us with.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your personal data

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

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.
  • To administer the website and personalise your browsing experience
  • Send you both non-marketing and marketing communications which we think may be of interest to you, if you have specifically agreed to this;
  • Deal with enquiries and complaints.

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules or where this is required or permitted by law.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Opting out of marketing

You can ask us to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us pursuant to a contract we have with you to provide a service.

Disclosures

Any information Indigogold holds is not shared with third parties without prior consent, except:

In order to fulfil our contractual obligations to you;

  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes (i.e. the performance of a contract) and in accordance with our instructions.

We may transfer your personal data outside the European Economic Area (EEA).
If we share your personal data with any third party in the course of providing you with our services, those third parties are required to process your data in accordance with contracts which comply with data protection legislation.

 Security

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We hold data in three main locations:

  • CRM software – this system is locked behind the initial log-on screen and has its own password to ensure security of data is maintained.
  • Within a secure offsite cloud server – this is protected with a secure password and firewall.
  • Office – any physical information is kept in a secure office; the room itself is locked when not in use. The building has door staff, access cards, and is monitored with CCTV.

In the event that there is a data breach, we will compile a report to investigate how the breach happened and notify all those affected (as well as the ICO). This will be done within two working days of being made aware of the breach. Even if a breach is not reported it will still be documented. Breaches are managed by the office manager.

Your rights

You are entitled to access your personal data, to have any information we hold rectified, have your data erased, have processing restricted or remove your consent to processing entirely, and control how the data is moved or transferred to a 3rd party. You also have the right to object to your data being processed and the right to not be subject to automated decision making (unless such automated decision making is required for us to perform your contract or you give us express consent to do so).

If requested, Indigogold will begin to action requests within two working days with an aim to have completed the request within a week. The individual will be informed once the request has been completed.

If you would like to discuss this further please contact us using the details listed above. Please note you will not have to pay a fee to access your personal data (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

 

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