Auxeris Ltd is committed to protecting the privacy and security of your Personal Data.
This privacy notice describes how we collect and use information about you that could be used to identify you (“Personal Data”), during and after your working relationship with us, in accordance with the General Data Protection Regulation (“GDPR”).
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practicable. It is important that you read and retain this notice or any updated version of this notice so that you are aware of how and why we are collecting or processing Personal Data about you and what your rights are under the data protection legislation.
Auxeris Ltd is a "data controller". This means we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the Personal Data we hold about you must be:
Used lawfully and in a transparent way;
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
Relevant to the purposes we have told you about and limited only to those purposes;
Accurate and kept up to date;
Kept only as long as necessary for the purposes we have told you about; and
HOW WILL WE USE PERSONAL DATA ABOUT YOU?
We will only use your Personal Data when the law allows us to. The GDPR explains what legal bases data controllers can rely on to legally process
Personal Data. Most commonly, the bases we will rely on to use your Personal Data are as follows:
Where you have consented to us using your Personal Data, such as when you send us your CV with Personal Data contained in it (“Consent”);
Where we need to perform the contract we have entered into with you, such as paying you your salary (“Contractual Obligation”);
Where we need to comply with a legal obligation, such as reporting fraudulent activity or other illegal actions (“Legal Compliance”); and
Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests, such as providing a list of our employees to investors as part of a due diligence process; (“Legitimate Interest”).
WHAT CATEGORIES OF YOUR PERSONAL DATA DO WE COLLECT, STORE AND USE?
Below we list all of the categories of Personal Data we collect, store and use. Not all of the following types of data will necessarily be collected from you but this is the full scope of team member Personal Data that we collect:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
Date of birth;
Marital status and dependants;
Next of kin and emergency contact information;
National Insurance number;
WHEN DO WE COLLECT YOUR PERSONAL DATA AND WHAT IS OUR LEGAL BASIS FOR COLLECTING IT?
Under the GDPR you are entitled to understand exactly when we collect different categories of your Personal Data and what legal justification we rely on in order to use that Personal Data.
Set out below is a table containing the different categories of Personal Data we collect, when we collect it (e.g. the activity that gives rise to the Personal Data collection) and the lawful basis for collecting, processing and using that Personal Data. Please refer to the section entitled "How Will We Use Personal Data About You?" to understand more about the legal basis we rely on.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described, but we will never process your data without a legal bases for doing so and it is for a related purpose. For further inquiries please contact your manager.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Failing to provide Personal Data
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our team).
SHARING PERSONAL DATA WITH THIRD PARTIES
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Personal Data.
We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.
”Third parties” include:
Third-party service providers (including contractors and designated agents) and other entities within our group. Examples of the services we may receive from third-parties that would require us to share team Personal Data could include: payroll, pension administration, legal services (such as SeedLegals), IT services, etc.;
Other entities in our group structure (if applicable);
Third parties in the context of a possible sale or restructure. In this situation we will so far as possible share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your Personal Data with the other parties if and to the extent required under the terms of the transaction; and
We may need to share your Personal Data with a regulator or to otherwise comply with the law. This may include making returns to HMRC or disclosures to shareholders such as directors’ remuneration reporting requirements.
If you would like to know exactly which third parties have been given access to your Personal Data by us, please contact your manager.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from your manager. If any data is shared to third parties they will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.
Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data to another party.
If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact your manager in writing.
No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.
IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY NOTICE, PLEASE CONTACT YOUR MANAGER.