Last modified: August 2020
For all questions contact firstname.lastname@example.org
1. Purpose of this Policy
2. Who are we and what do we do?
Weirdo Limited is a limited company number 12627238 registered in England & Wales. Its registered company address is 6th Floor, Charlotte Building, 17 Gresse Street, London, W1T 1QL.
3. How to contact us?
4. What personal information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. The types of personal data that we collect may include, for example:
- Identity Data: such as your first name, last name, previous names, age, marital status, title, date of birth, gender and CCTV images.
- Contact Data: includes postal address, email address and telephone number, the company you work for, your job title and department.
- Profile Data: includes username or similar identifier, password, your interests, survey and workshop responses, any personal information in content you provide on our website.
- Technical Data: includes IP address (a unique identifier for your computer or other device), mobile device ID, time zone setting and location and any other personal data we may obtain through you interacting with us.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and third parties acting on behalf and your communication preferences.
Sensitive and special categories of data
Where relevant to specific co-creation or research projects we may collect data about you which under the General Data Protection Regulation (GDPR) are considered Special Categories of Personal Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and information about your health, only where relevant to the specific nature of the project we are undertaking. We will get your express opt-in before collecting any of this personal information.
We do not collect any information about criminal convictions and offences, genetic/biometric data or trade union affiliation.
If you apply to us for any employment, the Recruitment Privacy Notice set out below will apply to your application.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We do not knowingly collect personal data from children under the age of 13 and we do not target our website to children under 13. If you are under 13 and want to ask us a question or use a Website in any way that means you have to provide any personal information, please get your parent or guardian to contact us or provide the information instead.
5. How is your personal data collected?
We use different methods to collect personal data from and about you including through:
- Direct interactions: you may give us your Identify Data, Contact Data and Profile Data by filling in forms or by corresponding with us by any method. This includes personal data you provide when you:
- Register your details or create an account on our website
- Subscribe to our service or publications
- Interact through our website
- Request marketing to be sent to you
- Enter a survey or participate in a task or workshop
- Apply for a job with us; or
- Visit our offices which have CCTV systems operated for the security of both our visits and staff.
- Automated technologies or interactions: when you use our websites we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. More information is set out in the Cookies section below.
- Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties: (a) analytics providers such as Google which has operations outside the EU; (b) social media platforms such as facebook which has operations outside the EU; and (c) hosting providers such as Squarespace which has operations outside the EU.
- Identity and Contact Data from publicly available sources such as Companies House, the Land Registry and the Electoral Register based inside the EU.
6. How do we use your personal information?
We may use your personal information for a number of different purposes and only when the law allows us to. In some countries, we are also required by law to state a “legal basis for processing” i.e. to tell you on what legal grounds or legal bases we are allowed to use your information, and this is set out below:
How will we use your personal information?
Type of data
Who do we share your information with?
Our legal basis for processing
To manage our relationship with you which may include:
(a) paying you for services that you provide us
(b) notifying you about changes to our terms or privacy notice
(c) asking you to leave a review or take a survey
(d) respond to enquiries through contact forms
We do not share your personal information for this purpose.
It is in our legitimate interest to use your personal information in such a way to ensure that we can keep our records updated, study how our users use our services and respond to your enquiry.
To enable you to take part in a survey, co-creation project or workshop.
Marketing and Communications Data
We may share your personal information for processing with third party collaboration tools (e.g. Obvi) which we use to facilitate your participation in co-creation and research projects or with our clients for whom we conduct co-creation projects and workshops.
It is necessary for our legitimate interests to provide you with access to projects and workshops, enabling us to review your profile and to contact you.
Where it is relevant to the needs of a specific co-creation or research project we may also look to collect personal data which, under the General Data Protection Regulation (GDPR) is considered as sensitive or special categories of personal data, such as data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or sexual orientation.
We will always ask you to opt-in to providing this information.
To make suggestions and recommendations to you about services, surveys, projects or workshops that may be of interest to you.
We do not share your personal information for this purpose.
It is necessary for our legitimate interests to provide you with relevant opportunities, develop our services and grow our business.
To use data analytics to improve our websites, services, marketing and user experiences.
We do not share your personal information for this purpose.
It is necessary for our legitimate interests to study our users and keep our websites updated and relevant.
To notify you about relevant communications, including project opportunities, company updates and industry news.
Marketing and Communications Data
If you have opted in to receiving marketing communications we may share your personal information with third party email and marketing providers who assist us in delivering our marketing campaigns.
We will get your express opt-in consent before we share your personal data with any company outside of Weirdo.
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see Section 7 below for further details about cookies.
To administer our business, protect our business and websites, ensure legal compliance and in connection with a business transition such a merger or acquisition by another company, or sale of all or a portion of our assets.
We may share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
Where we use your personal information to run our business, provide administration and IT services or to prevent fraud it is in our legitimate interest to do so.
For other purposes in this section it is our legal obligation to use your personal information to comply with any legal obligation imposed on us.
To verify information you provide to use when you apply for a job with us and to assess your suitability for the role, including checking references, background checks and your right to work in the UK.
For more information see our Recruitment Privacy Notice below.
We do not share your personal information for this purpose.
Necessary for our legitimate interest in hiring the most qualified and suitable people.
Necessary to comply with legal obligations.
Necessary for the performance of a potential contract with you.
7. Who do we share your personal information with?
Depending on the circumstances, we may share your personal information with the following entities:
- Third parties who undertake various activities to promote and support our Services. This includes social media platforms like Facebook, website and application support and hosting providers, marketing service providers, eCRM partners who manage our marketing emails, advertising platforms like Google - any of these third parties might be inside or outside your country of residence;
- Any law enforcement or regulatory body, government agency, court or other third party where we believe disclosure is necessary under applicable law or regulations;
- Any other person provided that you have given your consent.
We will not sell, distribute or lease your personal information unless we have your permission or are required by law to do so.
Cookies are small pieces of data that websites store on a device. Cookies can improve your browsing experience because they help websites remember preferences and understand how people use different features.
9. Third party links and services
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
External Third Parties include:
- Services providers based in the UK, EU and USA who provide IT, system administration services and other technology solutions.
- Professional advisers including lawyers, accountants and insurers based in the UK and EU who provide consultancy, accounting, legal, insurance and other professional services.
- HM Revenue and Customs, regulators and other authorities.
- Marketing providers such as Facebook and Google.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
10. How long do we keep your personal information for?
We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. 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, and the applicable legal requirements.
11. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect the personal information that we have under our control from:
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Websites and Services.
12. Transfers of personal data outside the EEA
Some of the personal information we collect about you through a Website will be transferred to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will ensure that the transfer is lawful and that there are appropriate security arrangements in place.
13. How to access your information and your other legal rights
To the extent provided by the law of your jurisdiction, you may (i) have the right to access certain personal information we maintain about you and obtain a copy of that information, (ii) update or correct inaccuracies in that information, (iii) object to our use of your personal information, and (iv) delete your personal information from our database. To exercise these rights, please contact us using the details above. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. A charge may be applicable before we provide you with a copy of any of your personal information that we maintain.
If you are located in the UK, EEA or Switzerland, you have the following rights in relation to the personal information we hold about you:
The right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
The right to request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
The right to object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
The right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
The right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
The right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, you can report it to the UK Information Commissioner’s Office (ICO) or any other supervisory authority or regulator responsible for data protection and privacy in your jurisdiction. If you are based in the UK, you can find details about the ICO on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.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.
If you want to exercise any of the rights set out above, please contact us at email@example.com.
14. 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 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.
15. Time limit to respond
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.
“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Cookies contain information that is transferred to your computer’s hard drive. For more details on cookies and similar technologies please visit All About Cookies.
Strictly necessary cookies.
These are cookies that are required for the operation of our Website.
They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. These cookies generally do not collect information that identifies a user.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie: Google Analytics
Purpose: Used to distinguish users
More information: http://www.google.com/intl/en/analytics/privacyoverview.html
From time to time we may also use functionality cookies. These are used to recognise you when you return to our Websites. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.
Recruitment Privacy Notice
1. Who will control your data?
If you are applying to work for Weirdo Limited we will be required to collect and process your personal data.
2. What will we hold and why?
We may collect the data including:
- Contact Data: name, address, email addresses and phone number;
- Qualifications details, skills, experience and employment history;
- Current salary and benefits information;
- Information about any disabilities which we need to make reasonable adjustments during the recruitment process; and/or
- Information confirming your right to work in the UK.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process as this allows us to manage the recruitment process and assess and confirm a candidate’s suitability for a role. We may also need to process data from job applicants to respond to and defend against legal claims.
In some cases, we need to process data to ensure that we are complying with our legal obligations such as checking a successful applicant’s eligibility to work in the UK before employment starts.
3. Sensitive and special categories of data
Weirdo may need to collect and process special or sensitive categories of data if your application to work with or for us is successful. This will be carried out in accordance with Part 2 of the Data Protection Act 2018.
This includes categories of information such as ethnicity, sexual orientation, disability or religion/belief. This data is used to monitor our recruitment to help ensure equality of opportunity and treatment and to carry out our obligations and exercise specific rights in relation to employment.
This information will only be collected with your further consent.
We may also need to obtain information concerning past criminal convictions or carry out financial checks depending on the role. This is to comply with contractual obligations to clients or regulatory requirements as an employer.
4. How will the data be stored and for how long?
We hold your data in a range of different places, including our IT systems (including email) which includes the holding of data on servers which may be outside the European Economic Area.
If you are not successful in your application we may store your personal data in case there are future suitable employment opportunities. You are free to withdraw your consent at any time and we will ask before we keep your application for this purpose.We will hold your data on file for 3 months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisations will hold your data on file for a further 12 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data will be deleted.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment in accordance with our internal staff data retention policy, of which you will be notified.
5. Where do you collect the data from?
We may collect your data from the following sources:
- Recruiters and agencies
- Identity documents you provide to us
- Telephone, virtual and in-person interviews with you
If offered a role we may, with your consent:
- Collect data from referees you provide and previous employers
- Collect data from background checker providers/criminal records checks (dependent on the role)
6. Who will see the data?
Your personal data may be shared internally with relevant employees including interviewers, relevant managers and IT staff. We will only share this information for purposes of the recruitment process or monitoring the fair treatment of applicants.
We will only share your data with third parties if your application is successful and you are offered employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
7. What if I don’t provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
8. Access to your personal data and other rights
As a data subject, you have a number of rights. You can:
access and obtain a copy of your data on request;
require the organisation to change incorrect or incomplete data;
require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please use the contact details below. If you believe that an organisation within the Mother Group has not complied with your data protection rights, you have the right to complain to your local regulator responsible for data protection and privacy matters.
9. How to contact us
In processing your personal data for the purposes of recruitment, we act as a data controller.
If you have any questions or want to exercise any of your legal rights, please contact us by sending an e-mail to firstname.lastname@example.org.