Cast USA Privacy Notice

Last Updated: 7 April 2021

Introduction

This Privacy Notice applies to all data collections and other data processing of Cast USA Limited. For the purposes of this Privacy Notice any references to Cast USA (or "us" or "we" or "our") means Cast USA Limited.

At Cast USA we take your privacy seriously, this Privacy Notice explains how we treat your personal data to maintain your privacy. It describes how we collect, use and process your personal data, explaining what we do with it whether we are in the process of helping you find a job, continuing our relationship with you after finding you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates or you are a Website Visitor.

This Privacy Notice applies to the personal data of Candidates, Clients, Contractors, Suppliers, Website Visitors and other people whom we may contact in relation to our Candidates or whom they have indicated as an emergency contact. It also applies to the emergency contacts of our Staff.

Cast USA Limited reserves the right to update this Privacy Notice at any time, please review the "Last Updated" details at the top of this page to determine when this Privacy Notice was last updated. Any change to this Privacy Notice will become effective on the "Last Updated" date indicated above. Cast USA Limited will make every effort to communicate any significant changes to you via email and/or by posting a notice on Cast USA's Site. Your continued use of Cast USA Limited's services will be deemed as acceptance of any amended Privacy Notice.

If you are dissatisfied with any aspect of our Privacy Notice, you may have legal rights and, where relevant, we have described these as well.

How We Use Your Personal Data

Cast USA Limited collect your personal data in order to facilitate the recruitment process, you are under no obligation to provide your personal data, however, if you do not provide your personal data we may not be able to provide you with certain services. We only ask for details that will genuinely help us to help you, we do not collect more information that we require to fulfil our stated purposes and will not retain it for longer than is necessary.

It is not our policy to seek sensitive personal data unless required for further recruitment purposes, legally required or reasonably necessary for an ongoing relationship with you. Sensitive data includes data concerning race or ethnic origin, physical or mental health, sexual orientation, religious beliefs, political opinion, trade union membership or criminal records and proceedings. We therefore suggest that you do not offer sensitive personal data of this nature unless specifically requested to do so. If you do provide sensitive personal data for any reason, we accept this as your consent to use such data in the ways described in this Privacy Notice.

The personal data we hold is dependent upon your relationship with us, the information below describes the personal data held, how it is collected and used, the systems it is held in, the period we hold it for, who it is shared with and the lawful basis for processing.

The information described below is in addition to any personal data we are required by law to process in any given situation.

Unless otherwise stated Cast USA Limited is the Data Controller for the personal data you provide. If you have any queries about how we handle your personal data, please contact us at gdpr@cast-usa.com.

Candidates

What Personal Data We Hold

Dependent on the circumstances and requirements we may collect some or all of the personal data listed below to enable us to offer you employment opportunities that are tailored to your interests, skill set, experience and expectations.

Name
Date of Birth
Contact Details;
- Address
- Telephone Number (Home)
- Telephone Number (Work)
- Telephone Number (Mobile)
- Email Address (Personal)
- Email Address (Work)
LinkedIn Profile
Job Title
Current Employer;
- Remuneration
- Pension
- Benefits
Desired Salary/Rate
Experience
Qualifications
Avatar
Photo Identification;
- Copy of Driving License
- Copy of Passport
Video
Telephone Conversation Voice Recordings

Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data

We collect your personal data in three primary ways:

Personal data provided by you, the Candidate;
Personal data we receive from other sources; and
Personal data we collect automatically.

1. Personal Data Provided by You

Cast USA Limited needs to know certain information about you to be able to provide a tailored service. This personal information enables us to provide you with the best opportunities and to improve your job search experience with us.

There are a number of ways you can share your personal information with us. These include, but are not limited to:

Entering your details on the Cast USA Limited website as part of the registration process;
Leaving a hard copy of your CV at a Cast USA Limited recruitment event, job fair or office;
Emailing your CV to a Cast USA Limited consultant or being interviewed by them; or
Applying for jobs through a job aggregator, which then redirects you to the Cast USA Limited website

2. Personal Data We Receive from Other Sources

In addition to personal data received directly from you Cast USA Limited also receive personal data about Candidates from other sources. These may include personal data received in, but not limited to, the following situations:

Your referees may share personal information about you with us;
Our Clients may share personal information about you with us;
We may obtain personal information about you from searching for potential Candidates from third-party sources, such as LinkedIn and other job sites; and
If you "like" our page on Facebook or "follow" us on Twitter we will receive your personal information from those sites.

3. Personal Data We Collect Automatically

When accessing our website or if you read or click on an email from us we may collect your data automatically, or through you providing it to us.

More information can be found here.

How We Use Personal Data

We use the personal data we hold about you to provide and personalise the services we offer, enabling them to be more relevant and useful to you. We use it in three primary ways:

Recruitment activities;
Marketing activities; and
To help us establish, exercise or defend legal claims.

1. Recruitment Activities

Our main area of work is recruitment, and as a Candidate, your personal data is processed for the purposes of providing you with work-finding services. This includes, but is not limited to:

Contacting you about job opportunities;
Assessing your suitability for those job opportunities;
Updating our databases;
Putting you forward for job opportunities (sending your information to Clients); and
Developing and managing our services and relationship with you.

2. Marketing Activities

We may, from time to time, send you information we think you may find interesting. We may wish to use your personal information for purposes including, but not limited to:

The development and marketing of other products and services;
Marketing our full range of recruitment services to you;
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think may be of interest to you; and
Displaying promotional excerpts from your details on Cast USA Limited's website(s) as a success story (only where we have obtained your express consent to do so).

We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we'll ask for this via an opt-in.

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time.

If you have opted out from our marketing communications, either via the unsubscribe link in the footer of marketing emails or through your website profile, it is possible that your personal data may be recaptured from public sources in an unconnected marketing campaign. While we will endeavour to ensure this does not happen there may be instances, from time to time, where it does and would appreciate your understanding in these instances.

Our marketing is based on what we think will serve our Candidates best. We may use your data to show you Cast USA Limited adverts and other content on other websites.

3. To Help Us Establish, Exercise or Defend Legal Claims

In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

How Long We Keep Your Data For (Retention)

We will keep your personal data for a period of three years after our last meaningful contact with you (or our last meaningful contact with the company or entity that supplies your services if they are provided via a third-party company or entity). Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept for the period required by law.

"Meaningful contact" means, for example, written or verbal communication between us and you or where you are actively using our online services, including, but not limited to, uploading your updated CV to our website. We also consider communication from you regarding potential roles, either written or verbal, or clicking through from, or replying to, any of our marketing emails as meaningful contact.

Who We Share Your Personal Data With

Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies;
Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;
Potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
Third-party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
Managed Service Provider (MSP) suppliers as part of our clients' MSP programmes;
Third-parties we have retained to provide services such as reference, qualification and criminal conviction checks, to the extent that these checks are appropriate and in accordance with local laws; and
If Cast USA Limited merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

Article 6(1)(f) states that Cast USA Limited can process your data where "processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third-party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."

In simpler language this is where Cast USA Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Candidate we believe it is reasonable to expect us to collect and use your personal information to provide recruitment services to you, to share your personal information with prospective employers and compare your skills against our current vacancies where you have either provided us with your information directly, posted your CV information on a job board or on professional networking sites. Once it looks like you may be offered a position with a prospective employer, they may want to check any information you have provided or to confirm your qualifications, experience or references. The providing of this information to prospective employers is required to help you, and other Candidates, get the jobs you deserve and allows us to function as a profit-making recruitment business.

We think it's reasonable to process your personal data to provide a tailored recruitment service, offering you, the Candidate, a more pleasant job search experience and ensuring you receive the most appropriate content for your job search.

While we don't believe any of the above activities prejudice you in any way – they enable us to provide the service you have engaged us for – you have the right to object to us processing your data on this basis.

Contractors

What Personal Data We Hold

Name
Date of Birth
Bank Details
Contact Details;
- Address
- Telephone Number (Home)
- Telephone Number (Work)
- Telephone Number (Mobile)
- Email Address (Personal)
- Email Address (Work)
LinkedIn Profile
Job Title
Current Employer;
- Remuneration
- Pension
- Benefits
Desired Salary/Rate
Experience
Qualifications
Avatar
Photo Identification;
- Copy of Driving License
- Copy of Passport
Video
Telephone Conversation Voice Recordings

Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data

We collect your personal data in three primary ways:

Personal data provided by you, the Contractor;
Personal data we receive from other sources; and
Personal data we collect automatically.

1. Personal Data Provided by You

There are a number of ways you can share your personal information with us. These include, but are not limited to:

Entering your details on the Cast USA Limited website as part of the registration process;
Leaving a hard copy of your CV at a Cast USA Limited recruitment event, job fair or office;
Emailing your CV to a Cast USA Limited consultant or being interviewed by them; or
Applying for jobs through a job aggregator, which then redirects you to the Cast USA Limited website

2. Personal Data We Receive from Other Sources

In addition to personal data received directly from you Cast USA Limited also receive personal data about Contractors from other sources. These may include personal data received in, but not limited to, the following situations:

Your referees may share personal information about you with us;
Our Clients may share personal information about you with us;
We may obtain personal information about you from searching for potential Contractors from third-party sources, such as LinkedIn and other job sites; and
If you "like" our page on Facebook or "follow" us on Twitter we will receive your personal information from those sites.

3. Personal Data We Collect Automatically

When accessing our website or if you read or click on an email from us we may collect your data automatically, or through you providing it to us.

More information can be found here.

How We Use Personal Data

We use the personal data we hold about you to provide and personalise the services we offer, enabling them to be more relevant and useful to you. We use it in three primary ways:

Recruitment activities;
Marketing activities; and
To help us establish, exercise or defend legal claims.

1. Recruitment Activities

Our main area of work is recruitment, and as a Contractor, your personal data is processed for the purposes of providing you with work-finding services. This includes, but is not limited to:

Contacting you about job opportunities;
Assessing your suitability for those job opportunities;
Updating our databases;
Putting you forward for job opportunities (sending your information to Clients); and
Developing and managing our services and relationship with you.

2. Marketing Activities

We may, from time to time, send you information we think you may find interesting. We may wish to use your personal information for purposes including, but not limited to:

The development and marketing of other products and services;
Marketing our full range of recruitment services to you;
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think may be of interest to you; and
Displaying promotional excerpts from your details on Cast USA Limited's website(s) as a success story (only where we have obtained your express consent to do so).

We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we'll ask for this via an opt-in.

Our marketing is based on what we think will serve our Contractors best. We may use your data to show you Cast USA Limited adverts and other content on other websites.

3. To Help Us Establish, Exercise or Defend Legal Claims

How Long We Keep Your Data For (Retention)

We will keep your personal data for a period of seven years after our last meaningful contact with you (or our last meaningful contact with the company or entity that supplies your services if they are provided via a third-party company or entity). Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of seven years your personal data will be kept for the period required by law.

Who We Share Your Personal Data With

Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies;
Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;
Potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
Third-party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job;
Managed Service Provider (MSP) suppliers as part of our clients' MSP programmes;
Third-parties we have retained to provide services such as reference, qualification and criminal conviction checks, to the extent that these checks are appropriate and in accordance with local laws; and
If Cast USA Limited merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

In simpler language this is where Cast USA Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

Article 6(1) (b) states that Cast USA Limited can process your data where "processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract".

In simpler language this is where Cast USA Limited have placed you in a role as a contractor and have a contract in place with you to fulfil that role.

As a Contractor we believe it is reasonable to expect us to collect and use your personal information to provide recruitment services to you, to share your personal information with prospective employers and compare your skills against our current vacancies where you have either provided us with your information directly, posted your CV information on a job board or on professional networking sites. Once it looks like you may be offered a position with a prospective employer, they may want to check any information you have provided or to confirm your qualifications, experience or references. The providing of this information to prospective employers is required to help you, and other Contractors, get the jobs you deserve and allows us to function as a profit-making recruitment business.

We think it's reasonable to process your personal data to provide a tailored recruitment service, offering you, the Contractor, a more pleasant job search experience and ensuring you receive the most appropriate content for your job search.

Clients

What Personal Data We Hold

The data we collect about Clients is actually very limited. Dependent on the circumstances and requirements we may collect some or all of the personal data listed below to enable us to fulfil our obligations to you as a client.

Name
Contact Details;
- Address
- Telephone Number (Home)
- Telephone Number (Work)
- Telephone Number (Mobile)
- Email Address (Personal)
- Email Address (Work)
LinkedIn Profile
Job Title
Current Employer
Telephone Conversation Voice Recordings
Video

Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data

We collection your personal data in three primary ways:

Personal data provided by you, the Client;
Personal data we receive from other sources; and
Personal data we collect automatically.

1. Personal Data Provided by You

Cast USA Limited needs to know certain information about you and your business to ensure that you have the best staff for your business.

There are a number of ways you can share your personal information with us. These include, but are not limited to:

Where you contact us proactively, usually by phone or email; and/or
Where we contact you, usually by phone or email, or through our consultants' business development activities.

2. Personal Data We Receive From Other Sources

In addition to personal data received directly from you Cast USA Limited also receive personal data about Clients from other sources. These may include personal information received in, but not limited to, the following situations:

Due diligence checks;
Marketing intelligence;
Delegate lists at relevant events; and
Other third parties, for example Candidates that provide your details to act as a referee for them.

3. Personal Data We Collect Automatically

When accessing our website or if you read or click on an email from us we may collect your data automatically, or through you providing it to us.

More information can be found here.

How We Use Personal Data

We use the personal data we hold about you to provide and personalise the services we offer, enabling them to be more relevant and useful to you. We use it in three primary ways:

Recruitment activities;
Marketing activities; and
To help us establish, exercise or defend legal claims.

1. Recruitment Activities

Our main area of work is recruitment, and as a Client, your personal data is processed for the purposes of providing you with employee-finding services. This includes, but is not limited to:

Providing you with Candidates, Recruitment Process Outsourcing (RPO) services and MSP programmes;
To contact you in relation to recruitment activities;
Keeping records of our conversations and meetings, to provide targeted services to you; and
Processing your data for the purpose of targeting appropriate marketing campaigns.

2. Marketing Activities

We may, from time to time, send you information we think you may find interesting. We may wish to use your personal information for purposes including, but not limited to:

The development and marketing of other products and services;
Marketing our full range of recruitment services to you;
Sending you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think may be of interest to you; and
Displaying promotional excerpts from your details on Cast USA Limited's website(s) as a success story (only where we have obtained your express consent to do so).

We need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we'll ask for this via an opt-in.

Our marketing is based on what we think will serve our Clients best. We may use your data to show you Cast USA Limited adverts and other content on other websites.

3. To Help Us Establish, Exercise or Defend Legal Claims

How Long We Keep Your Data For (Retention)

We will keep your personal data for a period of three years after our last meaningful contact with you. Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept for the period required by law.

"Meaningful contact" means, for example, written or verbal communication between us and you or where you are actively using our online services. We also consider communication from you regarding potential roles, either written or verbal, or clicking through from, or replying to, any of our marketing emails as meaningful contact.

Who We Share Your Personal Data With

Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies;
Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers; and
If Cast USA Limited merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

In simpler language this is where Cast USA Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Client we believe it is reasonable to expect us to collect and use your personal information to provide the best recruitment services to you.

Supplier

What Personal Data We Hold

We need a small amount of information from our Suppliers to ensure our business relationship runs smoothly. We may collect some or all of the personal data listed below.

Name
Contact Details
- Telephone Number (Work)
- Telephone Number (Mobile)
- Email Address (Work)

Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data

We collect personal data when entering into an agreement with you and during the course of our work with you.

How We Use Personal Data

We use the personal data we hold about you in 4 primary ways:

To contact you in relation to our agreements;
To offer services to you or to obtain support and services from you;
To perform certain legal obligations; and
To help us to establish, exercise or defend legal claims.

How Long We Keep Your Data For (Retention)

We will keep your personal data for a period of three years after our last meaningful contact with you (or our last meaningful contact with the company or entity that supplies your services if they are provided via a third-part company or entity). Difference laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept for the period required by law.

"Meaningful contact" means, for example, written or verbal communication between us and you or where you are actively using our online services. We also consider clicking through from, or replying to, any of our marketing emails as meaningful contact.

Who We Share Your Personal Data With

We may share this information with any of our group companies and associated third parties such as our service providers and organisations to whom we provide services.

Lawful Basis For Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

In simpler language this is where Cast USA Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Supplier we believe it is reasonable to expect us to collect and use your personal information for the purposes outlined above.

Website Visitor

What Personal Data We Hold

Dependent on the circumstances and requirements we may collect some or all of the personal data listed below to enable us to fulfil our obligations to you as a website visitor.

Technical Information;
IP Addresses;
Information about what types of device you use to connect to our website; and
How you interact with our website.

Please note the above list of personal data we may collect is not exhaustive.

How We Collect Personal Data

We collect your personal data when you browse our website. We also collect personal information when you contact us via the website, for example by completing the contact us form.

We collect the data automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here.

How We Use Personal Data

We use the personal data we hold about you to monitor and improve the website experience for website visitors.

How Long We Keep Your Data For (Retention)

We will keep your personal data for a period of three years after you visit our website. Different laws may require us to keep your personal data for different periods of time, where a law requires we keep your personal data for a period in excess of three years your personal data will be kept for the period required by law.

Who We Share Your Personal Data With

Where appropriate, and in accordance with local laws and requirements, we may share your personal data with the following categories of people:

Any of our group companies;
Tax, audit, or other authorities, we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third-party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
Marketing technology platforms and suppliers;
If Cast USA Limited merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

Lawful Basis for Processing

Article 6 of the General Data Protection Regulation (GDPR) requires that we process all personal data lawfully, fairly and in a transparent manner.

In simpler language this is where Cast USA Limited has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.

As a Website Visitor we believe it is reasonable to expect us to collect and use your personal information to provide a positive browsing experience.

Your Rights

The General Data Protection Regulation (GDPR) provides the following rights for individuals:

The right to be informed;
The right of access;
The right to rectification;
The right to erasure (to be forgotten);
The right to restrict processing;
The right to data portability;
The right to object;
Rights in relation to automated decision making and profiling; and
The right to withdraw consent.

1. The Right to Be Informed

Individuals have the right to be informed about the collection and use of their personal data in a concise, transparent, intelligible and easily accessible way that uses clear and plain language. This Privacy Notice serves to provide this information.

Where personal data is obtained from third-party sources we will endeavour to inform the individual of this privacy information in a timely manner and no later than one month after receiving the data.

2. The Right of Access

Under the GDPR, individuals have the right to obtain:

Confirmation that their data is being processed;
Access to their personal data; and
Other supplementary information.

This right of access has been provided to allow individuals to access their personal information, so they are aware of and can verify the lawfulness of the processing.

To find out if we hold any of your personal information, and what data we hold, a Subject Access Request (SAR) can be submitted.

If we do hold your personal information we will:

Provide a description of it;
Explain why we are holding it;
Explain who it could be disclosed to; and
Let you have a copy of the information in an intelligible form.

Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.

3. The Right to Rectification

Individuals have the right to request that any inaccurate personal data is rectified or completed if it is incomplete. Personal data is considered to be inaccurate if "it is incorrect or misleading as to a matter of fact". This request can be made either verbally or in writing.

When a request for rectification is received we will take reasonable steps to confirm the identity of the individual making the request and to satisfy ourselves that the data provided is accurate and that rectification of the data is required. When considering the accuracy of the data you have the right to restrict the processing of your personal data until its accuracy has been established. Details of this right can be found here.

When we are satisfied of the accuracy of the new data we will update it within our systems. If we have shared the inaccurate personal data with third-parties, we will notify them of the rectification unless this is impossible or involves disproportionate effort.

We will inform you of the outcome of your request within one month of receipt of your request. Where a request is complex, or a number of requests have been received from you, the time to respond may be extended by a further two months. If we extend the time period we have to respond to your request, we will inform you of this within one month of receipt of the request and explain the reasons for the extension.

We retain the right to refuse to comply with a request for rectification if the request is "manifestly unfounded or excessive". Alternatively, we may request a "reasonable fee" to deal with requests considered to be "manifestly unfounded or excessive".

Where we refuse to comply with the request we will, without undue delay and within one month of receipt of the request, inform the individual of:

The reasons why