Privacy Policy | Ocean Red Partners

Privacy Statement

This Privacy Policy (“Policy”) explains how your information is collected, used and disclosed by Ocean Red Partners (Ocean Red Partners Limited) ( “We” or “Us” or “our”). This policy applies where we are acting as a Data Controller, where we determine the purposes and means of the processing of that personal data, for example with respect to the personal data of our website visitors, service users, clients, partners etc…

Privacy Statement Summary:

Who will use my data?	Ocean Red Partners Limited
Who are we?	Ocean Red Partners is a recruitment company and a recruitment business as defined in the Employment Agencies and Employment Business Regulations 2003 (our business). that provides its services globally to world leading brands in the Energy and Financial Technology sectors. As such, we process data in order to provide our services as a recruitment agency and meet our contractual obligations to both prospective employers and candidates for any roles. We will store and process your data in order to allow us to provide our services to you. We will also send any relevant details to authorities such as HMRC, Inland Revenue and any other organisation that requires them by law.
What for?	As a recruitment company we collect and process data in order to carry out our fundamental function as a recruitment agency. The sole purpose of our business is to collect personal information of job applicants and to connect them with potential employers.
What will happen if I contact you?	If you contact us as a candidate looking for work, we will use your information to send you the information that you have requested and updates, job vacancies and other information that we think you will be interested in. If you contact us as a client with possible vacancies to fill or with other related requests, we will use your information to send any requested information as well as updates and other information that we think you will be interested in as well as updates relevant to the positions advertised.
What data will be stored?	As an applicant, client, or employee, we will store your personal details such as application forms, identity documents and bank details in order to provide our services to you. We may also collect personal data about you from third parties, such as references supplied by former employers. As a potential employer, we will store any data required in order to provide our services to you and meet any contractual obligations. This might include potential contact information for example.

What data will be shared?	We will only share any data that is particularly relevant to our process in order to provide the services that we offer. We will only share information with the third parties detailed in this policy.
How long?	Your data will be stored for up to 5 years following the last contact we have with you, after which time your data will be deleted. For more information please refer to our Data Retention Policy.
Who can access my data?	We will never sell, share or otherwise distribute your data to any other third party other than as described here. We will share your information with any regulator or legal body that requests it as well as any parties relevant to the application process. Whether that be client companies with possible vacancies, or applicants to any roles.
How is my data kept secure?	We will store your data on secure UK based servers which will be processed in the UK. We use industry standard security protocols/technology to secure your data.

About This Privacy Policy

This policy sets out how we will collect, store and process the information that you provide to us, information we collect as a result of our interaction, the information we collect about you from other sources, or information we service about you by using the information we hold.

The General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principles. These say that personal data must:

Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than is necessary
Processed in accordance with the rights of the data subjects
Be protected in appropriate ways
Not be transferred outside the UK , unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously, this document describes our approach to data protection.

This policy helps to protect us from data security risks, including:

Breaches of For instance, information being given out inappropriately.
Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Any other risks inherent in the collection, storage, or processing of your data

Who We Are And How To Contact Us

Ocean Red Partners is registered in the United Kingdom and is registered with the Information Commissioner’s Office. The data protection lead and Data Protection Officer (DPO) Under Article 37 of the GDPR is Richard Twumasi. You can contact us in any of the following ways:

Name: Richard Twumasi

Company name: Ocean Red Partner Ltd Email:gdpr@oceanredpartners.com

Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Who This Policy Applies To

This policy relates to data subjects of Ocean Red Partners including clients (potential employers),

candidates, workers and employees, and all other individuals. Processing of your data is required in order to offer you our recruitment and selection services. This policy applies to individuals who have shared their data with Ocean Red Partners, either as a customer, candidate, employee, supplier or in any other capacity.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

Names of Individuals
Contact details
Postal addresses
Email Addresses
Telephone numbers
Other information as required

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

The Information you provide when you contact us
When you contact us in order to discuss using our services
Information we collect about how you use the website
Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
Information that is given and stored as part of our ongoing relationship
Information we collect as a result of our interaction
Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
Information we collect from our conferences
Information we derive from information we collect about you – for example where we derive your email address from your name and company name combined

We do not routinely collect or process sensitive data about you however where this is the case we will ensure we take appropriate precautions to protect your data.

How your information will be used – Our Lawful Basis

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new client

(a) Identity

(b) Contact

(a) Performance of a contract with you.

(b) In our legitimate interests.

(d) with your consent

To process and deliver our services you request including recruitment and employment services, managing payments, fees and charges, and to collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you.

(b) In our legitimate interests.

(d) with your consent

To manage our ongoing relationship with you which will include notifying you about changes to our terms, recruitment services, or privacy policy, to maintain our records

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation,

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

(d) with your consent

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

(b) with your consent

To use data analytics to improve our website, products/services,

(a) Technical

(b) Usage

Necessary for our legitimate interests to define types of

marketing, customer relationships and experiences		customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and	(a) Identity	(a) Necessary for our
recommendations to you about	(b) Contact	legitimate interests to develop
goods or services that may be of	(c) Technical	our products/services and
interest to you	(d) Usage (e) Profile	grow our business (b) with your consent

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), employment details, and other data collected as part of any application for employment. We may take personal information from:

Information that you provide to us when registering with our website (including your email address)
Information that you provide when completing your application (including your name, gender, date of birth and any educational details and employment details you provide)
Information that you provide to us when signing up to any lists to receive correspondence from
Information we collect from other sources such as the internet, social media, commercial databases, other companies, and other third parties
Information we derive from information we collect about you – for example where we derive your email address from your name and company name combined
Information relating to any vacancies, jobs, or employment you accept Personal data we receive will be used for the purposes it was provided, including:
To respond to queries from you regarding vacancies and employment
To manage and administer the relationships between you and us
To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
To obtain feedback from you regarding us
Tell you about any place of work changes e.g shift patterns, new assignments or any other changes regarding your Job Role.

In accordance with your preferences, we will use your data for the purpose it was collected and where we have your consent or an appropriate lawful basis may use your personal information to provide you with marketing information about services, promotions and offers that may be of interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any services we provide to you.

You will only receive marketing communications from us if you have:

Requested information from us
If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
You have not opted out of receiving marketing
Where we have an appropriate lawful basis

How to change your preferences

We operate in line with GDPR data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at any time.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data will be collected, stored and processed primarily in the UK, where we transfer your data outside the UK, we ensure that appropriate technical and organisational safeguards are in place to protect your data. Your data will be stored for a period of 5 years after our last interaction. Your data might be stored for up to 7 years in order to meet our legal obligations and protect our interests – this period is defined in our Data Retention policy.

In order to provide our services we may use carefully selected third parties. These third parties may operate outside the UK, if this is the case we will ensure we have in place appropriate safeguards to protect your data.

We may also use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the UK, if this is the case we will ensure we have in place appropriate safeguards to protect your data.

We will only use your personal data 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 and/or we are acting as you would reasonably expect. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Our obligations

We are a Data Controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR in the way we use and share your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal
Request correction of your personal
Request erasure of your personal
Object to processing of your personal
Request restriction of processing your personal
Request transfer of your personal
Right to withdraw

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.

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.

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.plex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Parties

We may have to share your personal data in the EU and UK and with the parties as set out below for the purposes described in this document:

For candidates/workers – Prospective employers and companies that may offer you work and other relevant third parties
For clients – Candidates / employees / workers that may be interested in any vacancies and other relevant third parties

For all users of our site:

Companies where you have applied for a vacancy
Other companies we believe you would be interested in working for
Companies that may have vacancies that match your preferences
Service providers who provide IT and system administration
Other companies as required for us to provide our services to you ad/or our clients
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services etc..
Third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
Third parties as required to provide our services to you and our clients
Social media platforms
Other IT platforms and services as required to provide our services to you and to operate our company
Other companies where we have a legitimate interest and where we believe the purpose is consistent with the original purpose and always as you would reasonably expect

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Where required under GDPR we will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine.

Legitimate Interests

We have completed a detailed Legitimate Interest Assessment to ensure that sharing your information and processing your information as described here is reasonable and that we have an appropriate lawful basis.

For more information feel free to contact us at gdpr@oceanredpartners.com

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact Richard Twumasi at Ocean Red Partners.

We aim to process data protection requests within 30 days, SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

www.ico.org.uk

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