Privacy Policy

1.0 Introduction

We, Placing the People Direct Limited, are committed to safeguarding the privacy of our clients, prospective clients, website visitors, and service users. We respect the privacy of all applicants and are determined to protect the personal data of everyone who interacts with us. This privacy notice serves to inform you about how we collect and process your personal data, including when you visit our website, regardless of your location. Additionally, we will outline your privacy rights and how data protection laws serve to protect you.

It is essential that you read this privacy notice alongside any other privacy notices we may provide on specific occasions when we are handling your personal data, ensuring that you are fully aware of how and why we process your information. This privacy notice is intended to supplement other notices and does not override them.

2.0 Data Controller

We act as the data controller, responsible for your personal data, collectively referred to as "Company", "we", "us" or "our" in this privacy notice. Our contact details are [Insert address and email address]. For any data matters, please contact Angela Durrant at [Insert name and email address].

3.0 Third-party Links Outside of Our Control

Our website may include links to third-party websites, content, plug-ins, and applications. By clicking on those links or enabling those connections, you may allow third parties to collect or share data about you. We have no control over these third-party websites and are not responsible for their privacy statements.

When you exit our website, we encourage you to review the privacy notice of every website you visit.

4.0 Personal Data We May Collect

Personal data, or personal information, encompasses any information about an individual from which that person can be identified. For more information about personal data, you can consult the Information Commissioners Office. 

We may collect, use, store, and transfer different types of personal data about you, categorized as follows:

- Identity Data: including first name, last name, username, marital status, title, date of birth, gender, qualifications, and banking details.

- Contact Data: including billing address, delivery address, email address, and telephone numbers.

We may also collect, use, and share aggregated data, such as statistical or demographic information, for various purposes. Aggregated data may be derived from your personal data, but it is not considered personal data by law, as it does not directly or indirectly reveal your identity. For example, we might aggregate your usage data to determine the percentage of users accessing a specific feature on our website. However, if we combine or connect aggregated data with your personal data in a way that can identify you, we will treat that combined data as personal data, governed by this privacy notice.

5.0 Purpose for Collection of Personal Data

We utilize various methods to collect data from and about you, including:

Directly: You may provide us with your identity, contact, or financial data by completing forms or corresponding with us. This includes personal data you provide when you:

- Apply for our products or services;

- Subscribe to our services or publications;

- Request marketing communication.

Indirectly: Third parties may share your personal data with us, such as when you visit our website or social media through links found on other sites, or when you consent to a third party providing us with your details.

6.0 How We Use Your Personal Data

We will only use your personal data in a manner permitted by law. Most commonly, we will use your personal data in the following circumstances:

- Processing is necessary for a contract you have with us or for taking specific steps at your request before entering into a contract.

- Processing is required for performing a task in the public interest or in the exercise of official authority vested in the controller.

- You have given us consent for processing your personal data for one or more specific purposes.

- Processing is necessary to protect the vital interests of the data subject or another individual.

- Legitimate Interest: This refers to our interest in conducting and managing our business responsibly while ensuring the best service and secure experience for you. We carefully assess and balance any potential impacts on you (both positive and negative) before processing your personal data for our legitimate interests.

- Compliance with legal or regulatory obligations: This pertains to processing your personal data to fulfill legal or regulatory duties we are subject to.

7.0 Purposes for Which We Will Use Your Personal Data

We have detailed below, in a table format, how we intend to use your personal data, along with the legal bases we rely on for each purpose. Note that we may process your personal data based on multiple lawful grounds depending on the specific purpose of use. If you require details about the specific legal bases we rely on for processing your personal data where more than one ground is applicable, please contact us at [insert email address].

8.0 Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that a web server sends to a web browser, which is then stored by the browser. This identifier is sent back to the server each time the browser requests a page from that server. Cookies can be classified into two types: "persistent" cookies, which remain valid until their expiry date unless deleted by the user, and "session" cookies, which expire once the user session ends, specifically when the web browser is closed. 

While cookies typically do not store information that personally identifies a user, any personal data we collect and retain about you may be linked to the cookie information. We use cookies on our website judiciously, specifically those that are strictly necessary for the provision of our website and services. 

You have the option to configure your browser to refuse all or specific cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies, certain parts of this website may be inaccessible or may not function properly.

9.0 Change of Purpose

Your personal data will be used solely for the purposes for which we collected it, unless we reasonably determine that we need to use it for another motive that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose aligns with the original purpose, feel free to contact [insert email address]. 

In cases where we need to use your personal data for an unrelated purpose, we will notify you and clarify the legal basis that permits us to do so. It’s important to note that we may process your personal data without your knowledge or consent, in compliance with the prevailing rules, where this is mandated or authorized by law.

10.0 Who We Share Your Personal Data With

We may need to share your personal data with the parties specified in the table in paragraph 4 above for the stated purposes. If you are an Applicant, sharing your personal data with Clients may be necessary for assessing your eligibility for various roles. 

This includes providers based in the UK who serve as processors, delivering IT and system administration services; professional advisers, including lawyers, bankers, auditors, and insurers also based in the UK, who provide consultancy, banking, legal, insurance, and accounting services; and HM Revenue & Customs, regulators, and other authorities based in the United Kingdom that may require reporting on processing activities in specific circumstances. 

Additionally, third parties may be involved if we choose to sell, transfer, or merge parts of our business or assets. Should changes occur, the new owners may process your personal data similarly to what is outlined in this privacy notice. We expect all third parties to maintain the security of your personal data and comply with the law. We only permit third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

11.0 Data Security

We strive to implement reasonable security measures designed to protect your personal data from unintentional loss, unauthorized use, access, alteration, or disclosure. Access to your personal data is strictly limited to those employees, agents, contractors, and other third parties who require it for business reasons. These individuals are instructed to process your personal data as directed, adhering to a duty of confidentiality. 

We have established procedures to manage any suspected personal data breach and will inform you and the relevant regulator of any breach in compliance with legal obligations.

12.0 Data Retention

We will maintain your personal data only for as long as necessary to fulfill the purposes for which it was collected, which includes satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for your personal data, we evaluate factors like the amount, nature, and sensitivity of the personal data, potential risks of harm from unauthorized access or disclosure, the reasons for processing your personal data, and whether those purposes can be met through alternative means, along with relevant legal requirements. Details regarding retention periods for different categories of your personal data can be requested by contacting us via email.

13.0 Your Legal Rights

13.1 Unless exempt under data protection laws, you possess the following rights concerning your personal data: 

- The right to request a copy of your personal data that we hold; 

- The right to request corrections if your personal data is inaccurate or outdated; 

- The right to request the erasure of your personal data when retention is no longer necessary; 

- The right to withdraw consent for processing at any time, if consent was the basis for processing; 

- The right to request that we provide you with your personal data and, where feasible, to transmit that data directly to another data controller (this is known as the right to data portability), where applicable; 

- The right to request a restriction on further processing where a dispute exists concerning the accuracy or processing of your personal data; 

- The right to object to our processing of personal data, where applicable, especially where processing is based on our legitimate interests or for tasks in the public interest or official authority, including direct marketing or research and statistics. 

To exercise any of these rights, please reach out to [insert name] at [insert email address].

13.2 No Fee Required – With Some Exceptions

You won’t incur fees to access your personal data or to exercise your rights. However, we may impose a reasonable administrative fee if we believe your request to be unfounded, repetitive, or excessive. Otherwise, we may refuse to comply with such requests in those situations.

13.3 What We May Need From You

To confirm your identity and ensure your right to access your personal data, we may request specific information from you. This serves as a security measure to protect your personal data from unauthorized disclosure. We might also reach out for additional information to expedite our response.

13.4 Time Limit to Respond

We aim to respond to all legitimate requests within one month. Occasionally, if your request is complex or if multiple requests are made, it may take longer; in such cases, we will notify you and keep you informed.

14. Changes to This Notice and Your Duty to Inform Us of Changes

This privacy notice was last updated on 1 February 2021. Please inform us promptly if any of your personal data changes during your relationship with us, as it’s crucial that the personal data we hold about you is accurate and up-to-date.

15.0 Queries, Requests, or Concerns

To exercise your rights, or if you have queries or complaints related to this policy or any matter concerning data protection between you and us, please first contact [insert name] at [insert email address]. If this does not resolve your complaint satisfactorily, you have the right to lodge a complaint with the Information Commissioner's Office at 03031231113 or via email at https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.