Privacy Notice
This Privacy Notice describes how we collect and use personal information about you, in accordance with the UK General Data Protection Regulation (UK GDPR).
It applies to individuals who interact with us, including visitors to our website, clients, prospective clients, business contacts, suppliers, contractors, and other individuals whose personal data we process.
We are a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
This Privacy Notice does not form part of any contract. We may update this Privacy Notice at any time but if we do so, we will make an updated version available on our website as soon as reasonably practical.
It is important that you read and retain this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using that information and what your rights are under the data protection legislation.

Definitions
In this Privacy Notice the terms below have the following meanings.
“We”, “us”, “our” — Chain Side Ltd, a company incorporated and registered under the laws of England and Wales, company number 16720114, having its registered office at Dept 6258 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP.
“Personal data”, “personal information” — any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).

Data protection principles
We will comply with data protection law, which says that the personal information we hold about you must be:
  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold about you
Depending on the nature of our relationship with you, we may collect, store and use the following categories of personal information:
  • Personal contact details such as name, title, addresses, telephone numbers and email addresses.
  • Date of birth.
  • Gender.
  • Identification and compliance information (such as National Insurance number, tax status or regulatory confirmations, where applicable).
  • Payment and financial information where required to make or receive payments.
  • Records relating to our business relationship with you.
  • Information about your use of our website, systems or communications platforms.
  • Photographs or audiovisual material, where relevant.
  • Information required to assess regulatory, legal or compliance obligations.

How is your personal information collected?
We collect personal information directly from you when you interact with us, for example through our website, correspondence, meetings, contractual arrangements or the provision of services. We may also collect personal information from third parties, such as professional advisers, service providers, public registers, regulators, or other counterparties. Such collection is only possible if it complies with applicable data protection laws, and this Privacy Notice.

How we will use information about you
We will only use your personal information when we have relevant lawful basis for this. Most commonly, we will use your personal information in the following circumstances:
  1. Where it is necessary to perform a contract with you or take steps at your request prior to entering into a contract.
  2. Where we need to comply with a legal obligation imposed by law.
  3. Where it is necessary for legitimate interests pursued by us or a third party and you interests and fundamental rights do not override those interests.
  4. We may also use your personal information in the following situations, which are likely to be rare:
  5. Where we need to protect your interests (or someone else's interests).
  6. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information
The situations in which we will process your personal information are listed below.
  • Managing and administering our relationship with you.
  • Entering into, performing and managing contracts.
  • Business management, planning, accounting and auditing.
  • Organising meetings, events and communications.
  • Compliance with legal, regulatory and tax obligations.
  • Maintaining our public activities, communications and marketing where relevant.
  • Managing IT systems, security and access controls.
  • Preventing fraud and ensuring network and information security.
  • Dealing with legal disputes, claims or regulatory enquiries.
  • Protecting our legitimate business interests.
Some of the above grounds for processing may overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide services to you, enter into or perform a contract with you, or we may be prevented from complying with our legal or regulatory obligations.

Change of purpose
We will only use your personal information 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.

How we use particularly sensitive personal information
Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation, or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information in the following circumstances:
  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations or exercise our rights.
  3. Where it is needed in the public interest.
  4. Where it is necessary to protect you or another person from harm.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Situations in which we will use your sensitive personal information
The situations in which we will process your particularly sensitive personal information are listed below.
  • Managing situations involving incapacity or health-related issues, where relevant to our relationship with you.
  • Where we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.

Do we need your consent?
We do not need your consent if we rely on different lawful basis for your personal information processing in accordance with our written policy, in particular, to carry out our legal obligations or exercise our legal rights.
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract or interaction with us that you agree to such a request for consent.
We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. We do not envisage that we will hold information about criminal convictions.

Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
We are allowed to use automated decision-making in the following circumstances:
  1. Where we have notified you of the decision and given you one month to request a reconsideration.
  2. Where it is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights.
  3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.

Data sharing
We may have to share your data with third parties, including third-party service providers and other entities within our 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 information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?
The following categories of third parties may receive your personal data from us:
  • Payroll and accounting providers.
  • Government authorities and regulators.
  • Insurance providers.
  • IT and communication service providers.
  • Training and development providers.
  • Occupational health and safety providers.
  • Legal and compliance advisors.
  • Travel and expense management providers.
  • Our group or affiliated companies.
  • Background check or verification service providers, where relevant.

Which third-party service providers process my personal information?
Third parties include third-party service providers (including contractors and designated agents) and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?
We may share your personal information with other group entities for internal reporting, business reorganisation or restructuring, system maintenance, and data hosting purposes.

What about other third parties?
We will only share your personal information with other third parties where we have your knowledge and consent, or another lawful basis.
In particular, we may need to share your personal information with a regulator or to otherwise comply with the law.

Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention
How long will you use my information for?
We will only retain your personal information 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 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.
  • The applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that 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 information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
  • Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
To exercise any of these rights, please contact us in writing.

No fee usually required
You will not have to pay a fee to access your personal information (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 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information 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 information 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 us in writing. 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.
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