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Uptake General Privacy Notice

Created: 25 May 2018

Updated: October 2023 

 

This privacy policy tells you what to expect when Uptake collects personal information. It applies to information we collect about:

  1. Our clients, visitors to our website, and any other people who use our services (e.g., who subscribe to our newsletter or request a publication from us)
  2. Job applicants
  3. Consultants and Independent Principals

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

 

Responsibilities

Maxine Smith is the Managing Director with overall responsibility for data privacy.

 

Review process

We keep our general privacy policy under regular review. This general privacy policy was last updated in October 2023.

If you have any questions, suggestions or feedback, please contact privacy@uptakestrategies.com.

 

1. The data we collect 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, given name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone number
  • Financial Data includes bank account
  • Transaction Data
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
  • Profile Data includes your username and password, feedback and survey responses
  • Usage Data includes information about how you use our website, products and services
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preference

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We only collect any Special Categories of Personal Data about job applicants (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). This personal data may also include information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

2. Our clients, visitors to our website and any other people who use our services

In most cases, we will process the personal data of visitors to our website and people who use our services under the legal basis of the processing being necessary for the performance of a contract or the processing being in our legitimate business interests. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

 

Purpose / ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new client or create an account with usIdentity

Contact

Performance of a contract with you
To provide you with client quotes or bids for our business servicesIdentity

Contact

Transaction

 

Performance of a contract with you
To manage and administer the client business services we provide to you, including issuing and paying invoices, chasing payment or debt recoveryIdentity

Contact

Transaction

Financial

 

Performance of a contract with you

Necessary for our legitimate interests

To manage and administer contact forms submitted to us

To contact you following submission of a contact form

Identity

Contact

Marketing and communications data

Necessary for our legitimate interests
To manage and administer our newsletter

To analyse and monitor  statistics generated by our newsletter including email opening and click data

Identity

Contact

Marketing and communications data

Necessary for our legitimate interests
To manage and administer any contact with us via social media channels e.g., via private or direct messageIdentity

Contact

Marketing and communications data

Necessary for our legitimate interests
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Identity

Contact

Technical

Necessary for our legitimate interests
To manage and administer complaintsIdentity

Contact

 

Performance of a contract with you

Necessary for our legitimate interests

 

  • 2.1. – Opting out

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you. You can also contact us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

  • 2.2. – Our third parties

We may share your personal data with third parties for the purposes above. We use the following:

  • MailChimp, a secure third-party cloud database, to store the data (email address, first and last name) of anyone signing up to our newsletter, and to deliver it.
  • ShareThis to manage our social media interactions.
  • Google Suite to manage and host our email.

 

  • 2.3 – Website functionality

Our website search queries and results are logged anonymously by Google Analytics to help us improve our website and search functionality. No user-specific data is collected by either Uptake or any third party.

We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

 

3. Job applicants

Uptake is the data controller for the information you provide during the recruitment process unless otherwise stated. The legal basis by which we process your data is to fulfil our contractual obligations to you. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

 

Purpose / ActivityType of dataLawful basis for processing including basis of legitimate interest
To manage and administer your application.

To communicate with you about the recruitment process including shortlisting.

Identity

Contact

Marketing and communications data

Performance of a contract with you

Necessary for our legitimate interests

To assess your skills, qualifications and suitability for the role you have applied for including assessing experience, carrying out interviews, requesting referencesIdentity

Contact

Marketing and communications data

Performance of a contract with you

Necessary for our legitimate interests

To manage and administer a work preference questionnaire which may be sent to our recruiters for assessmentIdentity

Contact

Performance of a contract with you

Necessary for our legitimate interests

To allow you to participate in assessment days, complete tests or occupational personality profile questionnairesIdentity

Contact

Performance of a contract with you

Necessary for our legitimate interests

To carry out background and pre-employment checks, where applicable.

 

Identity

Contact

Financial

Performance of a contract with you

Necessary for our legitimate interests

To confirm your identity

To confirm your right to work in the United Kingdom

To confirm your qualifications

Identity

 

Contact

 

Performance of a contract with you

Comply with legal obligations

Performance of a contract with you

To keep records related to our hiring processes.

 

Identity

Contact

Financial

Performance of a contract with you

Necessary for our legitimate interests

To comply with legal or regulatory requirements.Identity

Contact

Financial

Comply with legal obligations
To assess whether you have any conflicts of interestIdentity

Contact

Financial

Performance of a contract with you

Necessary for our legitimate interests

 

  • 3.1. – Sensitive personal information

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

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

 

  • 3.2. – How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes any criminal records declaration and records of any security checks and references.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained by us for a period of six months. If you say yes, we will proactively contact you should any further suitable vacancies arise.

Information generated throughout the assessment process, for example interview notes, is retained by us for six months following the closure of the campaign.

How we make decisions about recruitment

Final recruitment decisions are made by the recruitment team. All of the information gathered during the application process is taken into account.

You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing office@uptakestrategies.com

 

4. Consultants and Independent Principals

Trusted, expert external consultants supply services to Uptake in order to fulfil our clients’ requirements under long-term consulting service contracts. For the purposes of our trading agreement between the external consultants and Uptake the details we need to retain are as follows:

  • Full name
  • Company address
  • Mobile phone/ contact details
  • Bank account details
  • Any other relevant details, e.g., professional insurance

Where relevant, we will also retain the home address of the consultant if this also operates as the company address for the purposes of posting documents and other relevant items ahead of company business, as required.

 

5. Change of purpose

We will only use your personal data 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 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, where this is required or permitted by law.

 

6. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

 

7. Disclosures of your personal data

We may share your personal data with parties as set out in the sections above. We also make the disclosures to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 and in accordance with our instructions.

 

8. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

9. Data security

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.

We have 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.

 

10. Data retention

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 with 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.

 

11. Your rights

Under the UK General Data Protection Regulation, 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

  • 11.1. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

  • 11.2. 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  • 11.3. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

12. Complaints or queries

Uptake tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy policy was drafted with brevity and clarity in mind. It does not provide exhaustive details of all aspects of Uptake’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to make a complaint about the way we have processed your personal information, you can contact ICO, the statutory body which oversees data protection law, there is a link to the relevant section of their website here.

 

13. Links to other websites

This privacy policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

 

14. Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://uptakestrategies.com/cookie-policy/.

 

15. How to contact us

If you want to request information about our privacy policy you can email us or write to:

Uptake

Index House

St George’s Lane

Ascot

Berkshire

SL5 7ET

United Kingdom