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BPE Design & Support Ltd, trading as BPE is committed to protecting your personal information when you are using our services, including this website. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including, in particular, the General Data Protection Regulation. Please read this policy to understand how your personal information will be treated.
How we use your information
This privacy notice tells you what to expect when BPE collects personal information. It applies to information we collect about:
· visitors to our websites;
· complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry;
· people who use our services, e.g. who subscribe to our newsletter or request a publication or enquire about our services;
· people who notify under the Data Protection Act; and
· job applicants and our current and former employees.
Visitors to our website
When you browse this website, you do so anonymously, unless you have previously indicated that you wish BPE to remember your personal information. We use a third-party service, Google Analytics, to collect standard Internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
A cookie is a small amount of data, which often includes a unique identifier, which is sent to your computer browser from a website’s computer and is stored on your computer’s hard drive. Cookies allow our website to recognise your computer or access device each time it is used to visit our website and to keep count of how often you return to the website. If you do not know what cookies are, or how to control or delete them, then we recommend you visit https://www.aboutcookies.org/ for detailed guidance.
We use two types of “cookies” to collect information. The first type of cookie is called a “session” cookie, which is temporary and is deleted automatically once you leave the BPE’s website.
We use a session cookie to remember your log-in for you (if applicable). These we deem strictly necessary to the working of the website. If these are disabled then various functionality on the site will be broken. More information on session cookies and what they are used for at http://www.allaboutcookies.org/cookies/session-cookies-used-for.html
Google Analytics – persistent cookies for site analytics and performance – we use this to understand how the site is being used in order to improve the user experience. User data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at https://support.google.com/analytics/answer/6004245
We use a third-party provider, Campaign Monitor, to deliver our monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information regarding their security and where they store their data please go to https://www.campaignmonitor.com/trust/
Security and Performance
The website is hosted with Heart Internet and this is their GDPR FAQ about where their data is stored https://www.heartinternet.uk/blog/gdpr-and-heart-internet-frequently-asked-questions/. The website has full SSL certification on the website provided by Starfield Technology. This is their information regarding security/storage. https://www.secureserver.net/help/privacy-center-27875?prog_id=504762
On many of the pages of the site you will see ‘social buttons’. These enable users to share or bookmark the web pages. There are buttons for: Twitter and LinkedIn . In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of BPE. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including when you are on the BPE website. So if you click on any of these buttons, these sites will be registering that action and may use that information. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information. We use a third-party provider, Lee Peck Media Limited, to manage our social media interactions.
External web services
We use a number of external web services to display content within our web pages, including Flickr, SlideShare and YouTube. This is not an exhaustive or complete list of the services we use, or might use in the future, when embedding content, but these are the most common. As with the social buttons we cannot prevent these sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc.
People who telephone us
When you call BPE by telephone we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.
Some emails that we send you have no tracking in at all, some emails we can track, at an individual level, to see whether the user has opened and clicked on the email.We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant does not want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not identify any complainants unless the details have already been made public.
People who use BPE’s Services
We have to hold the details of the people who have requested our services in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have used our services to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to use our services, they can unsubscribe at any time and are given an easy way of doing this.
Visitors to BPE’s Colden Common Offices
Visitors to BPE’s Offices will be asked to register basic details on arrival using a tablet based application called Swiped-On. Data is stored in the US with AWS. Further information is provided here; Security & Additional Security Information. Data is exported and sent to Sub-Processors that fall within the EU/US Privacy Shield or in the case of one of their sub-processors, entering into the EU Standard Contractual Clauses with them.
Service providers reporting a breach
Public electronic communications service providers are required by law to report any security breaches involving personal data to BPE. If we are advised of any breach that affects the data that we hold about you, we will inform you as soon as possible, and at least within 48 hours.
Job Applicants, current and past employees
BPE is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information, please contact us at Admin@bpe-ds.com.
All of the information you provide during a recruitment process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for, but it might affect your application if you do not.
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way that can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Our hiring managers shortlist applications for interview. They will be provided with your name or contact details or with your equal opportunities information if you have provided it.
We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by BPE.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
· Proof of your identity – you will be asked to attend our office with original documents, we will take copies. For your convenience, this will be done at the interview.
· Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies. For your convenience, this will be done at the interview.
You will be asked to complete a criminal records declaration to declare any unspent convictions.
We will contact your referees, using the details you provide in your application, directly to obtain references.
We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).
If we make a final offer, we will also ask you for the following:
· Bank details – to process salary payments
· Emergency contact details – so we know who to contact in case you have an emergency at work
· Membership of an existing pension scheme – so we can send you a questionnaire to determine whether you are eligible to re-join your previous scheme.
Whilst your information is held on our system, we will ensure that it is held securely and we take all appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of the information. We regularly review our information collection, storage and processing practices and our security measures to guard against unauthorised access.
Transfer of your information
We will not transfer any information collected from you to any third party without expressly seeking your consent before doing so, except in cases where we are required to disclose the information in order to comply with the law or any court order.
Your rights of access
Under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), you have rights as an individual which you can exercise in relation to the information we hold about you.
You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Complaints or queries
BPE Design tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of BPE Design’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office in their capacity as the statutory body that oversees data protection law – www.ico.org.uk/concerns
Access to Personal Information
BPE tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Act or the Regulation. If we do hold information about you, we will:
· give you a description of it;
· tell you why we are holding it;
· tell you to whom it could be disclosed; and
· let you have a copy of the information in an intelligible form.
To make a request to BPE for any personal information we may hold you need to put the request in writing addressing it to our compliance department or by writing to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the compliance department.
Disclosure of Personal Information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organization concerned and with other relevant bodies.
You can also get further information on:
- agreements we have with other organizations for sharing information;
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymized statistics;
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date
- links to other websites
Children’s online privacy information
BPE does not knowingly collect personal information from persons who are under 16 years of age. By agreeing to use our products or services, you represent that you are 16 years or older.
Links from our website
Some pages of our website contain external links. You are advised to verify the privacy practices of such other websites. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal information, without assuring yourselves of the privacy practices of other websites.
This BPE is governed by the laws of England and Wales and any dispute in respect thereof shall be subject to the exclusive jurisdiction of the courts of England and Wales.