Privacy Notice,•About us,•Why we have your information,•Onwhat legal basis we have your information,•Google disclosure,•Sharing your personal data,•Storage and disposal of your personal data,•Your rights,Introduction,We at the Access Group know it is a big responsibility to protect yourpersonal ,data.
This Privacy Noticeis meant to help you understand what information we ,collect, why we collect it, and how you can update, manage, export, and delete ,your information.,We may from time to time update this Privacy Notice, where we deem it ,appropriate, we will seek to notify you about the changes, however, we ,recommend you review this page periodically.,This Privacy Notice was last updated on: 18May 2023,th,Download a copy ofour Privacy Notice [PDF],About us,The ‘Access Group’is made up of numerous legal entitieswhich are wholly owned ,subsidiaries of The Access Technology Group Limited (company registration ,05575609).
Our primary trading entity isAccess UK Ltd(company registration ,2343760)–the registered address for both is:The Armstrong Building, 10 ,Oakwood Drive, Loughborough, LE11 3QF, United Kingdom.,Forthis Privacy Notice, Access UK Ltd is the controllerof the personal data ,which is processed by it as a controller.Other Access Groupentities may become ,a joint controller of your information from time to time.,Our G roup Data Protection Officer is Danielle Hefford.
To contact us regarding our ,use of personal data, you may email us atAccess.DPO@theaccessgroup.com,We have appointed Core Computer Consultants Ltd (registration number: 91755) ,as our EU representative under Article 27, EU GDPR.
Our representative can be ,contacted by email at Core.DPO@theaccessgroup.com,Why we have your information,We process personal data to fulfil our contractual obligations to our customers ,and tootherwiseimprove andmarket our solutions.,There are various ways in which we may obtain your personal data.,For example, because:,•an organisation you work for uses one of our solutions;,•an organisation you have engaged with uses our solutions to provide or ,otherwise make available a service to you;,•you have used one of our solutions where we process your data in our ,capacity as data controller;,•youhave contacted us;,•you work for us;,•you visited our website;,•your personal data was provided to us by a third party;or,•as a result ofother lead generating activities done by us.,On what legal basis we have your ,information,We will only ever process your personal data where we have a lawful basis to do ,so.
We have expanded upon the reasons for us processing your personal data ,below.,Where an organisation you work for uses one of our ,solutions,If you use our solutions through your employer, for example, our HR, Payroll, or ,eLearning solutions, then we will process your personal data as aprocessor(your ,employer is the controller).,We recommend you read your employer’s relevant privacydocumentationfor ,information explaining what personal data is collected, and what for, etc.,,Third parties may also processyour personal data(on our behalf).
The details of ,these third parties will be included in the contract we hold with the controller(your ,employer).,Tofulfil our contractual obligations with the controller, we may contact you from ,time to time regarding the solution.
For example, regarding scheduled or non-,scheduled downtime, or an update that you should know about(‘service ,messages’).
,Some of our solutions also have the ability to capture your feedback regarding ,use of the solution.
Where this is enabled by your employer, and you choose to ,provide feedbackto us, we will process a limited amount of your personal data in ,our capacity as a controller.,Our lawful basis for processing this data is legitimate interests.
The legitimate ,interest sought is for us to understand how to improve the solution.
,We use a third party, InMoment (Wootric) to process this data.
InMoment is a ,company based in the United States;we have in place EU Standard Contractual ,Clauses supplemented with a UK International Data Transfer Addendum.,Where you have engaged with an organisation that ,uses one or more of our solutions,If you use our solutions via a third-party organisation;for example, to book a table ,at a restaurant,or to submit your CV to a recruitment agency, then we will process ,your personal data as aprocessor(the relevant third-party organisation is the ,controller).,We recommend you read the third-party organisation’srelevantprivacy ,documentationfor information explaining what personal data is collected, and ,what for, etc.,,Some of our solutions have dedicated privacy notices, where this is the case, these ,are accessible via ourSecurity Portalor alternatively, they may be accessible ,within the solution itself.,Third parties may also processyour personal data(on our behalf).
The details of ,these third parties will be included in the contract we hold with the controller.,Some of our solutions also have the ability to capture your feedback regarding ,use of the solution.
Where this is enabled by the organisation, and you choose to ,provide feedback to us, we will process a limited amount of your personal data in ,our capacity as a controller.,Our lawful basis for processing this data is legitimate interests.
The legitimate ,interest sought is for us to understand how to improve the solution.
,We use a third party, InMoment (Wootric) to process this data.
InMoment is a ,company based in the United States.
we have in place EU Standard Contractual ,Clauses supplemented with a UK International Data Transfer Addendum.,Where you have used one of our solutionswhere we ,process your data in our capacity as data controller,Weprovide a limited number of solutions where some or all of your personal data ,is processed by the Access Group in its capacity as a controller.
For example, ,DesignMyNight, sPROC, Adam Procureor Adam Housing.,Where you use one or more of our Access Products and we process all of your ,data in our capacity as data controller,the relevant Access Product will make its ,own dedicated privacy notice availableto you, save for where one of the ,exceptions belowapplies:,•Where you use any of our solutions and you’re an “administrator” user, we may ,collect your personal data in our capacity as a controller.
,In this case, the information we process is limited to: your first name.
surname.
,business email address.
location.
business phone number.
Access Product ,user role(s).
and last login date.,The lawful basis for processing your information is legitimate interests.
,The legitimate interest pursued is to share servicemessages pertaining to the ,solution that is used,and tomarket Access Group solutions which may be of ,interest to you.
,•Where youare a “Provider” on SProc, Adam Procure or Adam Housing-a,“Provider” meaning a user who has signed up to either SProc, Adam Procure ,and or Adam Housing to bid on opportunities, contract management and or ,payment purposes.,The lawful basis for collectingand sharing your informationwith Access Group ,customers whom have procured services from youas a Provideris ,contractual, as the processing is necessary for the performance of the ,contract with you.Where the Access Group customer processes your ,information outside of the relevant solution, they are doing so as an ,independent controller of your information.
,Where we use your information to market Access Group solutions which may ,be of interest to you, our lawful basis is legitimate interests.The legitimate ,interest pursued is to share service messages pertaining to the solution that is ,used, and to market Access Group solutions which may be of interest to you.,The information we will process for marketing purposes is limited to: business ,email address.
business phone number.
your name.
company name.
service ,category reference and which local authority you’re engaged with to provide ,services.,We use third party solutions to store and otherwise process your information,,they will therefore process your personal data on our behalf.,Where you have contactedus,If you contactus, for example, for technical support,to inquire about our ,solutions,or to download some of our content,we willrecord the contact made,and log necessary details of the interactionon our systems.We process any ,personal data collected via these methods as a controller.
,The data collected (which may be via telephone recording) may include your first ,and last name, the email addressand telephone numberyou use for business ,purposes, your job title,andyour employer.,Our lawful basis for processing your personal data in this case islegitimate ,interests.The legitimate interestspursued aretosupport usdeliveringon our ,contractual obligations (where applicable), internaltraining, to improve the quality,of our services,to make information available to you(including marketing),and,orto resolve any conflict resolution (where applicable).
,We use third party solutions to record and log the contactmade with us.
they will ,therefore process your personal dataon our behalf.,Where you work for the Access Group,If you are an employee of ours, then we will process your personal data as ,acontroller.,Our lawful basis for processing is described in the dedicated employee privacy ,notice.,The relevant privacy notice is made available to you on our internal systems.
If ,you need help locating it, please ask your leaderor the DPO.,Where you visit our website,Your personal data, such as yourfirst and lastname, telephone number, email ,address, postal address, job title, employer and any other relevant contact details ,may be collected by us when you contact us usingany of our online forms.
,The lawful basisfor processing this information islegitimate interests.
The ,legitimate interest pursued is tokeep you informed about the solutions we offer ,which we think may be of interest to you(i.e., marketing).,We will also use cookies when you use our website and interact with us via email, ,to optimise your experience of us and our sites.
Please see ourCookie Policyfor ,more information.,Our lawful basis for processingpersonal data via cookiesisconsent.The ,legitimate interest sought is administration, statistical analysis, and enhancement ,of our website.,All personal data collected by us through our website is done on the basis that we ,are thecontroller.,Where you choose to share your personal data with us through the mechanisms ,available via the website, we will process that data using third party solutions.,These third parties will process your personal dataon our behalf.,Where your data was provided to us by a third party,We work with several reputable third parties for the purpose of them supplying ,to us business contact details to allow us to effectively market our solutions.
We ,may also collect information about you from other sources, for example, public ,sources or third-party social networksites.,Our lawful basis for processing islegitimate interests.The legitimate interest ,sought is the marketing of our available solutions.,All personal data obtained by us through our sources is done on the basis that we ,are thecontroller.,Where we obtain your personal data through these sources, we will process that ,data using third partysolutions.These third parties will process your personal ,data.,Where we collect your data through lead generating ,activities done by us,We may collect your personal data through various lead generating activities such ,as events, webinars, and other networking activities.,Our lawful basis for processing islegitimate interests.The legitimate interest ,sought is the marketing of our available solutions, or where relevant, to engage ,with you regarding a sales andpurchase agreement.,All personal data collected by us is done on the basis that we are thecontroller.,Where we obtain your personal data through these activities, we will process that ,data using third party solutions.These third parties will process your personal ,dataon our behalf.,Google disclosure,The Access Group has a variety of applications available via the Google Play Store, ,including SpitFire, PeopleXD, Applause, and others.,SpitFire’suse of information received, and any of our transfers of information to ,any other app, from Google APIs will adhere toGoogle API Services User Data,PolicyandGoogle’s Limited Use Requirements.,This same disclosure applies to all applications made available via the Google Play ,Store by the Access Group.,Further processing of your personal data,Where you use one of our solutions, we may derive or create anonymous data ,and information about your use of that solution.
This anonymised data will be ,further aggregated before being used either by us or a third party nominated by ,us to improve our products.
We may also commercialise this information, for ,example, to provide insights to third parties.,Our lawful basis for the anonymisation and aggregation process islegitimate ,interests,and we carry out this processing as a controller.,The legitimate interest pursued is statistical analysis to drive informed decision ,making, for the benefit of both the Access Group and other third parties.,Post completion of this anonymisation and aggregation process (which is ,irreversible), the data is no longer considered personal data for the purpose of ,applicable data protection legislation.
,Sharing your personal data,Wemay have to ad hoc share your personal data with regulators, law enforcement ,bodies, government agencies, courts or other third parties where we think it’s ,necessary to comply with applicable laws or regulations, or to exercise, establish ,or defend our legal rights.
,We have also partnered with reputable third parties to provide a best-in-class ,service offering to you and our wider customer base(which may include the ,marketing of Access Group solutions or compatible solutions provided by the ,Access Group’s trusted partners).Where sharing your personal data with our ,trusted partners means a transfer to a third country (without an adequacy ,decisionor adequacy regulations, as applicable) is to take place,we will ensure we ,put in place appropriate safeguards and supplementary measures to ensure an ,essentially equivalent level of protection (as compared to the UK and EU GDPR) to ,your personal data will be given.,We may also share your personal data with other members of the Access Group: ,we will only do this where we have a lawful basis for doing so, for,example,fulfilment of contractorlegitimate interests.Where the receiver of ,your personal data is an Access Group entity whichis in a third country without ,an adequacy decisionor adequacy regulation (as applicable),the transfer will be ,safeguarded by, at minimum, an intra-group agreement (which includes ,recognised model clausesand the UK’s IDTA).,Lastly, we may share your personal data with third parties in connection with a ,sale of the Access Group (or any part thereof).
Where that divested entity becomes ,acontroller of your information, they will supply or otherwise make available to ,you theirrelevant privacy notice.,Storage and disposal of your personal data,Where we have your personal data acting in our capacity as acontroller, we will ,delete your personal data in accordance with our data retention schedule ,(available via ourSecurity Portal), or as otherwise required by data protection ,legislation: including where you choose to exercise your rights as a data subject ,(see ‘Your Rights’section for more information).,Where we have your personal data acting in our capacity as aprocessor,we will ,delete your personal data in accordance with the controller’s instruction, or as ,otherwise required by data protection legislation.
If we are required by law to ,retain any of your personal data, we will inform the controller of this lawful ,obligation.,Your rights,We will process your personal data in accordance thePrinciples -external ,linkandIndividuals’ Rights -external linkof The General Data Protection ,Regulation (both the EU version (2016/679/EU) and UK retained version thereof).,Your data protection rights,Under data protection law, you have rights including:,•Your right of access-You have the right to ask us for copies of your personal ,information.,•Your right to rectification-You have the right to ask us to rectify personal ,information you think is inaccurate.
You also have the right to ask us to complete ,information you think is incomplete.,•Your right to erasure-You have the right to ask us to erase your personal ,information in certain circumstances.,•Your right to restriction of processing-You have the right to ask us to restrict the ,processing of your personal information in certain circumstances.,•Your right to object to processing-You have the right to object to the processing of ,your personal information in certain circumstances.,•Your right to data portability-You have the right to ask that we transfer the ,personal information you gave us to another organisation, or to you, in certain ,circumstances.,•Rights in relation to automated decision making.,To exercise any of these rights, please contact Access.DPO@theaccessgroup.com,Where werely on consent as a lawful basis of processing, you may withdraw your ,consent at any time by emailing us atAccess.DPO@theaccessgroup.com,Important note:If you feel we have not processed your data in accordance with ,the Principles and Rights of the individual under GDPR(EU or UK), please ,contactAccess.DPO@theaccessgroup.com(or our EU representative, ,Core.DPO@theaccessgroup.com) for our complaints procedure, or you may raise ,a complaint with theInformation Commissioners Office -external link(or other ,relevant supervisory authority) but we would like the opportunity to resolve any ,issues first.