Picked Group Limited is committed to protecting the privacy and security of your Personal Data.
Picked Group Limited is a "data controller". This means we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the Personal Data we hold about you must be:
Used lawfully and in a transparent way; Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes; Relevant to the purposes we have told you about and limited only to those purposes; Accurate and kept up to date; Kept only as long as necessary for the purposes we have told you about; and Kept securely
WHEN DO WE COLLECT YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR COLLECTING IT?
Under the GDPR you are entitled to understand exactly when we collect different categories of your Personal Data and what legal justification we rely on in order to use that Personal Data.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described, but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.
SHARING PERSONAL DATA WITH THIRD PARTIES
We may have to share your data with third parties, including third-party service providers and other entities in the group. 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 Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Personal Data.
We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.
”Third parties” include:
Third-party service providers (including contractors and designated agents) and other entities within our group. Examples of the services we may receive from third-parties that would require us to share team Personal Data could include: payroll, pension administration, legal services (such as SeedLegals), IT services, etc.; Other entities in our group structure (if applicable); Third parties in the context of a possible sale or restructure. In this situation we will so far as possible share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your Personal Data with the other parties if and to the extent required under the terms of the transaction; and We may need to share your Personal Data with a regulator or to otherwise comply with the law. This may include making returns to HMRC or disclosures to shareholders such as directors’ remuneration reporting requirements. If you would like to know exactly which third parties have been given access to your Personal Data by us, please contact our Data Protection Officer.
We have 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. Details of these measures may be obtained from our Data Protection Officer. If any data is shared to third parties they will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We will only retain your Personal Data 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.
In some circumstances we may anonymise your Personal Data 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 Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.
Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. Request correction of the Personal Data 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 Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below). Object to processing of your Personal Data 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 Data for direct marketing purposes. Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your Personal Data to another party. If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact our Data Protection Officer in writing.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data 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 our Data Protection Officer. 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 OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your Personal Data, please contact the DPO. 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.
DPO Name: Guy Thornton
DPO Email: email@example.com
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CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.
IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY NOTICE, PLEASE CONTACT OUR DATA PROTECTION OFFICER.