We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to applicable data protection law.
Key terms
It would be helpful to start by explaining some key terms used in this notice:
| We, us, our | SCSK Europe Ltd. |
| Personal data | Any information relating to an identified or identifiable individual |
| Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation |
Personal data we collect about you
We may collect and use the following personal data about you
• your name and contact information, including email address and telephone number and company details
• your job title
• details of our interactions and correspondence
• professional interests
• your professional online presence, e.g. LinkedIn profile
• Information about how you use our website, IT, communication and other systems
This personal data is required to provide services. If you do not provide personal data we ask for, it may delay or prevent us from providing services.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, or email and/or via our website. However, we may also collect information:
• directly from a third party, e.g.:
– your employer;
– credit reference agencies; or
– customer due diligence providers.
• from cookies on our website—for more information on our use of cookies, please see our cookie notice;
• via our IT systems, e.g.:
– door entry systems ; and
– automated monitoring of our websites and other technical systems, such as our computer networks and connections, and access control systems, communications systems, email and instant messaging systems.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:
• to comply with our legal and regulatory obligations;
• for the performance of our contract or to take steps before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
| What we use your personal data for | Our reasons |
| To provide services to you | For the performance of our contract or to take steps before entering into a contract |
| To prevent and detect fraud | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging |
| Conducting checks to identify our customers and verify their identity | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service at the best price |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract or to take steps before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
Who we share your personal data with
We routinely share personal data with:
• companies within the SCSK group;
• third parties we use to help deliver our services;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
• credit reference agencies;
• our insurers and brokers; and
• our bank/s.
We only allow our service providers to use your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. We may also share personal data with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area and the United Kingdom. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing services to your employer (or are otherwise dealing with your employer). Thereafter, we will keep your personal data for as long as is necessary:
• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law
We will not retain your personal data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.
Transferring your personal data out of the UK and EEA
We share your personal data within the SCSK Group. This will involve transferring your data outside the European Economic Area (EEA) (for EEA data) or the UK (for UK data).]
Whenever we transfer your personal data out of the EEA or 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 by the European Commission (or, in relation to UK data, countries that are deemed by the relevant authorities to provide an adequate level of protection for personal data).
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (or, in relation to the UK, contracts approved for use 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 EEA or the UK.
Further information
If you would like further information about data transferred outside the UK or EEA, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Access | The right to be provided with a copy of your personal data (the right of access) |
| Rectification | The right to require us to correct any mistakes in your personal data |
| To be forgotten | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object |
The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us.
If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. If you have any queries or concerns regarding your personal data, please contact us - see ‘How to contact us’ below. If you feel that we have not used your data correctly, or if you are unhappy with the way that we have responded to a request you have made you have the right to lodge a complaint with a local supervisory authority in your country of residence.
Changes to this privacy notice
This privacy notice was published on 22/03/2021 and last updated on 22/03/2021.
We may change this privacy notice from time to time—when we do we will inform you via our website.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you
Our contact details are shown below:
Our contact details
Vintners’ Place, 68 Upper Thames Street, London EC4V 3BJ
contact@scskeu.com
+44 (0) 20 7246 3660