1. Welcome
Presentus Limited (“Presentus”) is strongly committed to protecting personal data. This privacy statement describes why or how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others.
Personal data is any information relating to an identified or identifiable living person. Presentus processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose may differ.
This Privacy Notice tells you how we look after your personal data when you visit our website and at other points at which we collect your personal data. It tells you about your privacy rights and how the law protects you.
We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection. This document may also be described as a Fair Processing Notice.
Presentus is the data controller for your data. Our registered office is at The Workary, Croydon Road, Caterham, Surrey, England, CR3 6TR. You can contact us there or by email at hello@presentus-ttp.com or by telephone on 0203 987 3177.
Finding your way around this privacy notice
This Privacy Notice is set out at follows.
2. Guide to key terms used in this policy
The following terms have the following meanings.
| Term | Meaning |
|---|---|
| Data Controller | The person or organisation who decides why personal data is required and directs how it will be processed accordingly |
| Data Subject | Any living individual in the EU |
| DPO | Data Protection Officer. |
| GDPR | General Data Protection Regulation |
| Personal Data | Any information from which a particular living individual can be identified |
| Processor | A person or organisation which processes personal data on the instruction of a controller |
| Processing | Processing means any operation which is performed on / use made of personal data from collection through to deletion. |
| Sensitive personal data / Special category data | Information relating to a person's racial/ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, health, genetic data and/or biometric data for the purpose of uniquely identifying a living individual. |
3. Important information about us
Presentus is a recruitment software platform company that is registered in England and Wales, registered number is 13422953.
| Contact details | |
|---|---|
| Name or title of DPO: | Founder & CEO |
| Email address: | hello@presentus-ttp.com |
| Postal address: | The Workary, Croydon Road, Caterham, Surrey, England, CR3 6TR |
| Telephone number: | 0203 987 3177 |
We recognise that transparency is an ongoing responsibility so we will keep this privacy notice under regular review. This privacy notice was last updated in May 2022.
Making a complaint
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please Contact us in the first instance.
A request we would like to make of you
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 relationship with us.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. We will notify you if this is the case at the time.
4. Letting you know about our events
Presentus may hold events throughout the year, such as: –
- Round table events
- Seminars
- Webinars
- Marketing and demo events
Presentus may invite its members on such events. You may receive such invitations by post unless you have asked us not to contact you in this way (‘opted out’) or by email if you have consented to receive such invitations in this way.
Newsletters & Contact by Social Media
In addition, Presentus may contact you using the preferences you have expressed in your consent form.
5. The Type of personal data we collect about you
When we refer to collecting or using personal data, or personal information, we are referring to any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and share different kinds of personal data about you which we have grouped together in this table.
| Types of Data | Details |
|---|---|
| Identity Data | This includes - name, username or similar identifier, title, date of birth and gender, employer details |
| Contact Data | This includes billing address, delivery address, email address and telephone numbers. |
| Financial Data | This includes bank account and payment card details. |
| Transaction Data | This includes details about payments from and to you, and in some cases details of services you have obtained from us. |
| Technical Data | This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. |
| Profile Data | This includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. |
| Usage Data | This includes information about how you use our websites |
| Events Data | This includes your preferences in receiving information about (or invites to) events and your communication preferences. |
| Travel Data | This includes Identity Data, Contact Data, Transaction Data and the data available on a copy of your passport. |
| Special Category Data | This includes data relating to, information about your health. This may include personal data identifying racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; data concerning health; data concerning marital relations (‘sex life’) or sexual orientation. |
| Human Resources Data (‘HR Data’) | This includes Identity Data, Contact Data and Special Category Data for staff and volunteers. With regard to staff members this may also include Financial Data and Transaction Data. |
6. Where do we get your personal data from?
We use different methods to collect data from and about you. We have set this out in the table below.
| How we collect personal data | |
|---|---|
| Direct Interactions | You may give us your [Identity, Contact, Financial Data, marital data, religious data, educational data and children data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • Registration details • Request that details of events be sent to you • Filling in subscription forms on our websites • Apply for our products and services • Subscribe for publications • Give us some feedback |
| Automated technologies or interactions. | As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy on our website for further details. |
| Third parties or publicly available sources. | We may receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: • analytics providers such as Google based outside the EU |
Our website uses the following types of cookies:
- Google Analytics (for more information see Google’s Privacy Notice)
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.
7. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we have your consent to do so.
- Where we need to perform a contract which we are about to enter, or have entered into, with you.
- Where we need to comply with a legal or regulatory obligation.
- 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.
8. Purposes for which we use your personal data
We use your personal data when undertaking the following activities.
| Type of Activity | Purpose Description |
|---|---|
| Presentus member registration | Administration, governance and maintenance of membership records. |
| Financial Information Entry | 1. Registration for events 2. Payroll Data Entry into System 3. Accounts Payable |
| General Affairs activities | 1. For the functionality of the platform i.e. introducing candidates to potential employers |
9. Legal basis for using your personal data
We have set out below, in a table format, a description of particular activities in which we engage, and according to which we process personal data. Further, we have set out the legal basis which we rely on in order to do so. We have also identified our legitimate interests for processing personal data, where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need any further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Specific purpose or activity | Type of data used | Lawful basis for processing (Article 6 GDPR) | Lawful basis for processing (Article 9 GDPR) |
|---|---|---|---|
| For administrative purposes to register members with the company | Identity Data Contact Data Financial Data Transaction Data | Legitimate interest | |
| 1. Registration for events 2. Payroll Data Entry into System 3. Accounts Payable | Identity Data Financial Data | Legitimate interest | |
| 1. For the functionality of the platform i.e. introducing candidates to potential employers | Identity Data Financial Data Special category Data | Legitimate interest | Explicit Consent |
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 or seek your consent to do so
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where we are required, or permitted to do so by law.
11. International data transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded 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. For further details, see European Commission: ‘Adequacy of the protection of personal data in non-EU countries’.
- Where we use service providers in countries that have not been deemed to provide an adequate level of protection, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: ‘Model contracts for the transfer of personal data to third countries’.
- We have obtained your explicit consent.
Please Contact us if you wish to receive further information on the specific mechanism which we use when transferring your personal data out of the EEA or if you have any concerns.
12. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed and/or processed in an unauthorised manner. These measures include:
- Hard copies of personal data are securely managed and not left unattended.
- Presentus maintains a clear desk policy (meaning that confidential information is not left unattended e.g. papers containing confidential information is not left on desktops, laptops are not left unsecured and any confidential information is locked away when not in use).
- Personal data is always out of view of anyone who has not been granted access to it and it should be locked away outside core operating hours.
- Paper-based documentation containing personal data is disposed of in a secure manner when no longer required (i.e. via confidential waste bins or cross shredders).
- Systems holding personal data have controls and measures in place to keep the data secure, provide protection from malware infection and data backup in case of equipment failure.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational ‘need to know’. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
13. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the following criterion:
- 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; whether we can achieve those purposes through other means; and
- the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request Please contact us using link here on section 16, contact us.
In some circumstances, you can ask us to delete your data: see your right to Request Erasure below for further information.
In some circumstances, we may anonymise your personal data (so that you can no longer be identified through the data) for research or statistical purposes. According to the law, anonymous data is not classed as personal data, as the data cannot be used identify any given individual. As such, we are permitted by law to use anonymous data indefinitely without further notice to any data subject.
14. Description of your legal rights
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 your data is being lawfully processed.
- Request correction of the personal data that we hold about you. This enables you to request that any incomplete or inaccurate data which we hold about you is corrected, though we may need to verify the accuracy of the new data which you provide to us.
- 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 in the following circumstances: where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are legally required to erase your personal data. Please note, however, that we may not always be able to comply with your request of erasure due to specific legal reasons. If such circumstances arise, you will be notified at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) if our legitimate interest is overridden by your own interests and/or fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you consider our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to yourself or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note, this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you at the time if this is the case.
15. Exercising your legal rights
Data Subject Access Requests:
Administration fee could be 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 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.
Time limit to respond
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.
If you wish to exercise any of your other rights, please contact us using the link here XXXX by email.
16. Contact us
As mentioned above, we have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO using the contact details provided above
