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Privacy Policy

Our Privacy Policy

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by Apollo Solutions (“We” or “Us" or “Our”). This policy applies where we are acting as a Data Controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

We are committed to safeguarding the privacy of our website visitors and service users. We will never sell, share, or use your personal information other than as described here.

By using our website and agreeing to this Policy, you also consent to our use of cookies in accordance with the terms of this Policy.


By using our website and agreeing to this Policy, you also consent to our use of your data in accordance with the terms of this Policy.

This is an important and complex area. To provide guidance and reduce the amount of work you need to do, this document is split into two sections.


Privacy statement summary

Who will use my data?

Apollo Solutions

What for?

We will store and process your data in order to allow us to provide our services to you as a recruitment company or

 

1.Where we need to perform or take preparatory steps to perform the contract we have entered/shall enter into with you

 

2.Where we need to comply with a legal obligation; and

 

3.Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

What will happen if I contact you?

If you contact us as a candidate looking for work, we will use your information to send you the information that you have requested and updates, job vacancies and other information that we think you will be interested in.

 

If you contact us as a client with possible vacancies to fill or with other related requests, we will use your information to send any requested information as well as updates and other information that we think you will be interested in as well as updates relevant to the positions advertised.

 

What data will be stored?

As an applicant, client, or employee, we will store your personal details such as your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website, passport details, job history, interview notes and correspondence.

 

We may also collect personal data about you from third parties, such as references supplied by former employers.

 

As a potential employer, we will store any data required in order to provide our services to you and meet any contractual obligations. This might include potential contact information for example.

 

What data will be shared?

We will only share any data that is particularly relevant to our process in order to provide the services that we offer. We will only share information with the third parties detailed in this policy such as:

  • clients for the purpose of introducing candidates to them;
  • candidates for the purpose of arranging interviews and engagements;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  • subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you;
  • third party IT systems such as Bullhorn our CRM platform, Force24 our communications platform, Google for data storage and processing, and others as you would expect from a recruitment company.

How long?

Your data will be stored for up to 7 years following the last contact we have with you, after which time your data will be minimised, we only retain the information required to meet our legal obligations and protect our business.

 

For more information, please ask for our Data Retention policy.

Who can access my data?

We will never sell, share or otherwise distribute your data to any other third party other than as described here.

 

We will share your information with any regulator or legal body that requests it as well as any parties relevant to the application process. Whether that be client companies with possible vacancies, or applicants to any roles.

 

How is my data kept secure?

We will store your data on secure servers.

 

We use industry standard security protocols/technology to secure your data.

Where we transfer data outside of the UK, we ensure that the data remains safe and as secure as you would expect in the UK.  We will ensure appropriate SCC/DPR/TRIA etc. are in place as required.

We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services, recruitment information and other information you may be interested in. We will never sell, share or use your personal information other than as described here. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

 

About this Privacy Policy

The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than is necessary
  • Processed in accordance with the rights of the data subjects
  • Be protected in appropriate ways
  • Not be transferred outside the United Kingdom, unless that country or territory also ensures an adequate level of protection


We take these responsibilities seriously; this document describes our approach to data protection.


This policy helps to protect us from data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

Who we are and how to contact us

Apollo Solutions is registered in England: No: 06454181 and is registered with the Information Commissioner's Office. The Data Protection Lead is: Siba Oyetey. You can contact us in any of the following ways:


Email: siba@apollo-solutions.com


Phone: +44 (0)20 3167 3167


Website: https://www.apollo-solutions.com/


Address: The Warehouse, 212 New King’s Road, London, SW6 4NZ, United Kingdom



Who this policy applies to

This policy relates to data subjects of Apollo Solutions including clients (potential employers), candidates, workers and employees, and all other individuals. Processing of your data is required in order to offer you our recruitment and selection services. This policy applies to individuals who have shared their data with Apollo Solutions as either a customer, candidate, employee, supplier or in any other capacity.


It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

  • Names of Individuals
  • Postal addresses
  • Email Addresses
  • Telephone numbers
  • Other data required to our services

 

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

  • The Information you provide when you contact us
  • When you contact us in order to discuss using our services
  • Information we collect about how you use the website
  • Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
  • Information that is given and stored as part of our ongoing relationship
  • Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
  • Information we derive from information we collect about you - for example where we derive your email address from your name and company name combined
  • Other information we process in relation to our recruitment services

We do not routinely collect or process sensitive data about you, however, where this is the case we will ensure we keep that data safe as required under Article 9 of GDPR.


Our lawful basis - what this policy applies to

This section describes the lawful basis for processing your data and applies to all personal information collected, stored, and processed which relates to any individual.

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new client

(a) Identity, (b) Contact

(a)Performance of a contract with you.

(b)In our legitimate interests.

(c)Where we have a legal obligation.

(d)With your consent

 

To process and deliver our services you request including recruitment and employment services, managing payments, fees and charges, and to collect and recover money owed to us

(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications

(a)Performance of a contract with you.

(b)In our legitimate interests.

(c)Where we have a legal obligation.

(d)With your consent

To manage our ongoing relationship with you which will include notifying you about changes to our terms, recruitment services, or privacy policy, to maintain our records

(a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications

(a) Performance of a contract with you,

(b) Necessary to comply with a legal obligation,

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services 

(d) With your consent

 

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity, (b) Contact, (c) Technical

(a)Necessary for our legitimate interests for running our business, provision of administration and IT services, network security,

(b)To prevent fraud and in the context of a business reorganisation or group restructuring exercise,

(c) Necessary to comply with a legal obligation

(d) With your consent

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical

(a)Necessary for our legitimate interests to study how customers use our products/services, to develop them,

(b)to grow our business and (c)to inform our marketing strategy and with your consent

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical, (b) Usage

(a)Necessary for our legitimate interests to define types of customers for our products and services,

(b)to keep our site updated and relevant,

(c)to develop our business

(d)to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile

(a)Necessary for our legitimate interests to develop our products/services and grow our business and

(b)with your consent


As an employee / candidate / recruit / contractor etc.: We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), employment details, and other data collected as part of any application for employment. We may take personal information from:

  • Information that you provide to us when registering with our website (including your email address)
  • Information that you provide when completing your application (including your name, gender, date of birth and any educational details and employment details you provide)
  • Information that you provide to us when signing up to any lists to receive correspondence from
  • Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
  • Information we derive from information we collect about you - for example where we derive your email address from your name and company name combined
  • Information relating to any vacancies, jobs, or employment you accept


Personal data we receive will be used for the purposes it was provided, including:

  • To respond to queries from you regarding vacancies and employment
  • To manage and administer the relationships between you and us
  • To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
  • To obtain feedback from you regarding us
  • Tell you about any place of work changes e.g shift patterns, new assignments or any other changes regarding your job role.


In accordance with your preferences, we may also use your personal information to provide you with information about products, services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the services, opportunities, promotions and offers that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.

 

How to change your preferences

We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at any time.

 

Scope of agreement

By submitting your personal data on this site or as required for us to provide products and services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.

We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

 

How we store and process your data

Your data will be collected, stored and processed primarily in the UK. Where we transfer your data outside the UK, we ensure that appropriate technical and organisational safeguards are in place to protect your data. Your data will be stored for a period of time after our last interaction - this period is defined in our Data Retention policy.

In order to provide our services, we may use carefully selected third parties. These third parties may operate outside the UK. If this is the case, we will ensure precautions are in place to protect your data.

We may also use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the UK. If this is the case, we will ensure precautions are in place to protect your data.

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 and/or we are acting as you would reasonably expect. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge.

 

Our obligations

We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data.

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

 

Third parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

For candidates/workers - Prospective employers and companies that may offer you work and other relevant third parties

For clients – Candidates / employees / workers that may be interested in any vacancies and other relevant third parties

For all users of our site:

  • Companies where you have applied for a vacancy
  • Other companies we believe you would be interested in working for
  • Companies that may have vacancies that match your preferences
  • Service providers who provide IT and system administration services
  • Other companies as required for us to provide our services to you and/or our clients
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services etc.
  • Third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you)
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
  • Third parties as required to provide our services to you and our clients
  • Social media platforms
  • Other IT platforms and services as required to provide our services to you and to operate our company, for example our CRM system Bullhorn and our communications platform Force24. We use a range of platforms as you would expect from a recruitment company
  • Other companies where we have a legitimate interest and where we believe the purpose is consistent with the original purpose and always as you would reasonably expect.


We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

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 such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

For more information, please refer to our Cookie Policy on the following link: https://www.apollo-solutions.com/cookie-policy/.

 

Legitimate interests

We have completed a detailed Legitimate Interest Assessment to ensure that sharing your information and processing your information as described here is reasonable and that we have an appropriate lawful basis.

 

Contacting us, exercising your information rights and complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact Siba Oyetey at siba@apollo-solutions.com.

We will process SARs within 30 days. SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

 

Our EU Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is: Instant EU GDPR Representative Ltd

Adam Brogden
contact@gdprlocal.com
Tel + 353 15 549 700
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street,  Lucan Co.  Dublin
K78 X5P8
Ireland


If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:


Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

www.ico.org.uk

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