Introduction

Able UK Ltd (“ABLE”, “we”, “us”, or “our”) is strongly committed to protecting personal data.  This privacy statement describes why and 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.  We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable living person.  ABLE 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.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. 

Collection of personal data

Visitors to our websites are generally in control of the personal data shared with us.  We may capture limited personal data automatically via the use of cookies on our website.  Please see the section on Cookies below for more information.

We receive personal data, such as name, title, company address, email address, and telephone and fax numbers, from website visitors; for example when an individual subscribes to updates or submits an enquiry or curriculum vitae to us.

Visitors are also able to send an email to us through the website. Their messages will contain the user’s name and email address, as well as any additional information the user may wish to include in the message.

We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Cookies

We use small text files called ‘cookies’ which are placed on your hard drives to assist in personalising and enriching your browsing experience by displaying content that is more likely to be relevant and of interest to you.  The use of cookies is now standard operating procedure for most websites.  However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them.  You need to accept cookies in order register on our website.  You may find other functionality in the website impaired if you disable cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish and you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

You can find out more details regarding our use of cookies below.

Types of cookie:

‘Session’ cookies remain in your browser during your browser session only, ie until you leave the website.

‘Persistent’ cookies remain in your browser after the session (unless deleted by you).

‘Performance’ cookies collect information about your use of the website, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous.  Performance cookies are used to improve how a website works.

‘Functionality’ cookies allow the website to remember any choices you make about the website (such as changes to text size, customised pages) or enable services such as commenting on a blog.

Use of cookies by ABLE:

The following table explains the way in which we use cookies on this website.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to:

• register for certain areas of the site;
• subscribe to updates;
• enquire for further information;
• distribute requested reference materials;
• submit curriculum vitae;
• monitor and enforce compliance with our terms and conditions for use of our website;
• administer and manage our website, including confirming and authenticating identity and preventing unauthorised access to restricted areas, premium content or other services limited to registered users;
• aggregate data for website analytics and improvements;
• Administering, managing and developing our businesses and services;
• Providing information about us and our range of services;
• Making contact information available to ABLE users;
• Identifying clients/contacts with similar needs;
• Describing the nature of a contact’s relationship with ABLE;
• Performing analytics, including producing metrics for ABLE leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals.

Unless we are asked not to, we may also use your data to contact you with information about ABLE’s business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to info@ableuk.com.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.  If there is an instance where such information may be shared with a party that is not a ABLE member firm, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual or a relationship with a business contact).

Security

We take the security of all the data we hold very seriously.  We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business.  As a result, personal data may be transferred outside the countries where we and our clients are located.  This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data.   We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.  The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

• Other ABLE member firms
  We may share personal data with other ABLE member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from ABLE member firms in different territories).  Our business contacts are visible to and used by ABLE users from other ABLE member firms to learn more about a contact, client or opportunity they have an interest in.

• Third party organisations that provide applications/functionality, data processing or IT services to us
  We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

• Third party organisations that otherwise assist us in providing goods, services or information
• Auditors and other professional advisers
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
  Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 14 May 2018.

Data controller and contact information

The data controller is Able UK Ltd (the limited company registered in England under registration no. 02386356 and with its head office address at Able House, Billingham Reach Industrial Estate, Billingham, TS23 1PX) and such other ABLE member firm that is a contracting party for the purposes of providing or receiving services.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer

Able UK Ltd

Able House, 

Billingham Reach Industrial Estate, 

Billingham, 

TS23 1PX

Email: info@ableuk.com

Phone: +(44)01642 806080

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data

You have a right of access to personal data held by us as a data controller.  This right may be exercised by emailing us at info@ableuk.com. We may charge for a request for access in accordance with applicable law.  We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 40 days).

Amendment of personal data

To update personal data submitted to us, you may email us at info@ableuk.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis).  To withdraw consent to our processing of your personal data please email us at info@ableuk.com or, to stop receiving an email from a ABLE marketing list, please click on the unsubscribe link in the relevant email received from us.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. Some of these rights will only be available from 25 May 2018.

If you wish to exercise any of these rights, please send an email to info@ableuk.com.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to info@ableuk.com.  We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.