Privacy Policy

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We are committed to protecting and respecting your privacy. Our Group includes our sister companies as defined in section 1159 of the UK Companies Act 2006 (our Group). This notice, together with our Terms and Conditions document, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course. Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of data protection legislation in force from time to time the data controller is Pangea Resourcing Limited of The Warehouse, 212 New Kings Road, London, SW6 4NZ, United Kingdom. 

We will use your personal information in the following circumstances (further detail outlined below):

• Where we need to perform or take preparatory steps to perform the contract we have entered/shall enter with you;
• Where we need to comply with a legal obligation; and
• 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

We collect the personal data of the following types of people to allow us to undertake our business:

• Prospective and live client contacts;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers.

We collect information about you to carry out our core business and ancillary activities.

This is information about you that you give us by filling in forms on our site www.axiom-ips.com, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, send us Biographical Information or CVs, download resources, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae and photograph, links to your professional profiles available in the public domain (e.g., LinkedIn, Twitter, business Facebook or corporate website, passport details, job history, interview notes and correspondence.) 

If customers can’t find it, it doesn’t exist. Clearly list and describe the services you offer. Also, be sure to showcase a premium service. 

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and referrals. In this case we will inform you we are holding your data and for what purpose we intend to retain and process it, by sending you this privacy notice, within a reasonable time. This is the earliest of:

• The first communication with you; or
• If the personal data is to be disclosed to someone else, before it is disclosed; or
• One calendar month from the date the data was obtained.

We work with third parties and may occasionally receive information about you from these third parties for the purposes of our on demand consulting services, recruitment services and ancillary support services.

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation;
• To provide you with information about other services we offer;
• Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data;
• We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation;
• We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations;
• We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.

Are your customers raving about you on social media? Share their great stories to help turn potential customers into loyal ones.

Our legitimate interests in collecting and retaining your personal data is described below:

• To maintain, expand and develop our business we need to record the personal data of prospective client contacts. Your personal data may be used for email marketing purposes to keep you informed about related industry news and articles, career advice, events, surveys, activities and services.

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time. Other Uses we will make of your data:

• to notify you about changes to our service;
• to ensure that content from our website is presented in the most effective manner for you and for your computer.

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We may use your Contact and Profile Data to form a view on what we think may be of interest to you. If you have requested information from us, and in the case that you have not opted out of receiving marketing, you may receive marketing communications from us. 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time or by clicking unsubscribe at the bottom of any marketing information received. We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process. 

We will share your personal information with:

• Any member of our group both in the EEA and outside of the EEA.
• Selected third parties including:
  1. clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  2. subcontractors including email marketing specialists, event organisers, payment and other financial service providers
  3. analytics and search engine providers that assist us in the improvement and optimisation of our site;
  4. credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Pangea Resourcing Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Pangea Resourcing Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;

1. to fulfil their legal obligations.

The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be transferred to third parties outside of the EEA for the purpose of our information and/or recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our information services, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. All information you provide to us is stored internally on our secure servers; any information that is stored on our CRM (Customer Relationship Management) software is also secured by a third party. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and will hold your personal data for up to 7 years after your last contact. We run data routines to remove data that we no longer have a legitimate business interest in maintaining. We do the following to try to ensure our data is accurate:

• Our website enables you to manage your data and to review whether the details we hold about you are accurate;
• Prior to making an introduction we check that we have accurate information about you;
• We keep in touch with you so you can let us know of changes to your personal data.

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:

• the nature of the personal data;
• its perceived accuracy;
• our legal obligations; and
• whether an interview or placement has been arranged.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so. For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms. Our current retention notice is available upon request.

You have the right to ask us not to process your personal data for marketing purposes. As above and where possible, we will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes. You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at compliance@axiom-ips.com. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. The GDPR provides you with the rights to:

• 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 in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

If you do grant consent, please note you can withdraw your consent to all or any one of the above purposes at any time by compliance@axiom-ips.com. Please note that all processing of your personal data will cease once you have withdrawn consent, but this will not affect any personal data that has already been processed prior to this point. Please allow up to 7 days to process. 

The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the GDPR. A subject access request should be submitted to compliance@axiom-ips.com. 

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice. 

 Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to our GDPR working group on compliance@axiom-ips.com.