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Privacy Notice For Alchemis Holdings Ltd

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PRIVACY NOTICE FOR ALCHEMIS HOLDINGS LTD
This is the full Privacy Notice for Alchemis Holdings Ltd and all associated companies within the Alchemis Group. It covers how we collect, process and manage any personal data that we hold for our Employees, Clients, Suppliers and any associated individuals, along with relevant information held on our CRM database. For visitors to our website only, please see the privacy policy published on there at https://www.alchemis.co.uk/privacy/
Alchemis is a Business Development Agency operating primarily within the Marketing Services Industry. We help Marketing Communications Agencies of all kinds by generating B2B new business opportunities for them.
Alchemis take your privacy very seriously. All data captured will be used and held in accordance with the General Data Protection Regulation 2016/679 (GDPR).
If you have any questions about this privacy notice or about any personal data we may hold about you, please contact the Data Protection Officer at info@alchemis.co.uk or write to us at Alchemis Holdings Ltd, Flitcroft House, 114-116, Charing Cross Road, London WC2H 0JR.

For the purposes of clarity, this notice has been broken down into four sections (listed below) and outlines what data we collect, why we collect it and how we manage it.

1. Employees, Ex-Employees and Potential Candidates
2. Clients and Potential Clients
3. Suppliers and Potential Suppliers
4. Personal Data Held on our CRM Database

Employees, Ex-Employees, Potential Employees

What is personal data?
Personal data relates to a living individual who can be identified from that data.

Why do we need your Personal Data?
In order to operate as a business, Alchemis needs to collect, process and retain relevant necessary personal information from its staff. This will include holding some data about former staff for a period of time after they leave, as well as certain relevant details from potential candidates that may have approached Alchemis for a job.
For this purpose, Alchemis is defined as the Data Controller.
Alchemis will collect and securely store certain information such as an employee’s name, address, phone number, bank account details, National Insurance Number, date of birth, etc which are either strictly necessary either by law, or in order to complete essential tasks – for example to process an employee’s salary.

How do we collect this Personal Data?
Most of this personal data is provided directly by the employee, but in some instances it may be provided from information a candidate has provided via a third party such as a recruitment consultant or through an source such as LinkedIn or an online job board.

Who has access to this Personal Data and how is it stored?
Any personal information that is collected by Alchemis will be stored securely (for example in a locked filing cabinet in our offices in the case of paper documents, or on a secure server in the case of electronic documents).
The owners of Alchemis Holdings Ltd will have access to these documents and are responsible for keeping them secure. Certain staff members may also have to access some of this information if it is strictly necessary. For example, to complete tasks such as processing an employee’s wages. Any owners and staff that manage personal information will do so in accordance with the General Data Protection Regulation 2016/679 (GDPR).
Some essential third parties may also have access to some of the personal data we hold for our employees. For example, our Accountants (who provide payroll services), our Pensions Provider, our Bank (so we can process employee salaries), Government or other such organisations who require this data by law (eg HMRC).
We may also provide essential personal data if requested by certain other organisations – for example if an employee is trying to rent a property and the landlord requests confirmation from Alchemis of certain details in order for the employee to do so. However, in these instances the management of Alchemis will confirm with the employee first before disclosing any personal information.

How long do we keep your data for?
Alchemis will not retain your personal data longer than necessary and it will be within the timeframes currently set out by the Government or other such organisations who require this data to be held by Alchemis by law (eg HMRC).
The current key retention periods outlined by the CIPD are listed below:
Accident Records: Minimum of 3 years since the last entry, or if it involves a child until they reach 21.
Income Tax and NI: Minimum of 3 years from the end of the financial year to which they relate.
Maternity and Paternity: Minimum of 3 years from the end of the tax year in which the leave ends.
Salary and Pay: Minimum of 6 years.
Working Time: 2 years.
Application and Recruitment Records: 6-12 months.
Parental Leave: 5 years from birth or adoption, or 18 years if the child receives a disability allowance.
Pension Benefits: 12 years from the ending of any benefit payable.
All Personnel Files and Training Records: 6 years from the end of employment.
Redundancy Records: 6 years.
Sickness Absence Records: A minimum of 3 months but potentially up to 6 years after employment ends.
After this point any personal data we hold will be securely destroyed in accordance with GDPR guidelines.

Queries About Your Personal Data and Subject Access Requests
If you have any queries with regard to the above practices please speak to your line manager (for current employees) or contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PRIVACY POLICY (for ex-staff and potential candidates) with a brief message outlining your query.
You have the right to see what personal data we hold about you. To obtain a copy of the personal information we hold about you, please email us at info@alchemis.co.uk with the subject heading SUBJECT ACCESS REQUEST.
You have the right to withdraw consent at any time to any of your personal data we may hold or process. To do this, please contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PERSONAL DATA and a brief message. Please note that this will be subject to any guidelines by the Government or other such organisations who require this data to be held by Alchemis by law (eg HMRC).
Alternatively you can also write to the Data Protection Officer, Alchemis Holdings Ltd, Flitcroft House, 114-116, Charing Cross Road, London WC2H 0JR.

If you feel any query you have has not been resolved you have the right to make a complaint to the Information Commissioners Office. For details please see see www.ico.org.uk

Clients, Ex-Clients and Potential Clients

What is personal data?
Personal data relates to a living individual who can be identified from that data.

Why do we need your Personal Data?
In order to operate as a business, Alchemis may need to collect, process and retain relevant necessary personal information from its clients. This will include holding some data about former clients for a period of time after they leave, as well as certain relevant details from potential clients that may have approached or been approached by Alchemis for the purposes of running a business development campaign.
For this purpose, Alchemis is defined as the Data Controller.
Alchemis may collect and securely store certain information such as the name, job title, business email and phone number, work address, etc of specific staff employed by its clients if they are involved in the administration of any work we do. We collect these details in order to complete essential tasks – for example to raise invoices, communicate with the client about campaign progress, etc. We may also collect these details if they necessary by law.
Most staff at Alchemis Holdings will have access to these details, although some information may be restricted. For example, a client’s bank account details will only be available to strictly necessary staff such as the business owners or the Finance Manager.
Essential third parties only, such as our Accountants, may have some access to certain personal details during the course of any work they carry out for Alchemis. For example, they may have access to the name and business email address for a member of staff at an Alchemis client whilst working on a shared software package to produce our accounts.
We will not share personal data with other third parties unless we are obliged to disclose personal data by law, or the disclosure is necessary for purposes of national security, taxation and criminal investigation, or we have your consent.

How do we collect this Personal Data?
Most of this personal data is provided directly by the client, but in some instances it may be provided from information provided on the client’s own website or via a third party such as Companies House, LinkedIn or a relevant B2B list or directory. Any data collected through a third party would be verified with the client by Alchemis and amended or removed as necessary.

How long do we keep your data for?
Alchemis will not retain your personal data for longer than is reasonably necessary. Data will be held within the timeframes currently set out by the Government or other such organisations who require this information to be held by Alchemis by law (eg HMRC).
If necessary we will retain data in order to resolve disputes, enforce our Terms & Conditions, provide customer support to you and offer further products and services to you if we believe there is a legitimate interest.

Queries About Your Personal Data and Subject Access Requests
If you have any queries with regard to the above practices please contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PRIVACY POLICY (for ex-clients and potential clients) with a brief message outlining your query.
You have the right to see what personal data we hold about you. To obtain a copy of the personal information we hold about you, please email us at info@alchemis.co.uk with the subject heading SUBJECT ACCESS REQUEST.
You have the right to withdraw consent at any time to any of your personal data we may hold or process. To do this, please contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PERSONAL DATA and a brief message. Please note that this will be subject to any guidelines by the Government or other such organisations who require this data to be held by Alchemis by law (eg HMRC).
Alternatively you can also write to the Data Protection Officer, Alchemis Holdings Ltd, Flitcroft House, 114-116, Charing Cross Road, London WC2H 0JR.
If you feel any query you have has not been resolved you have the right to make a complaint to the Information Commissioners Office. For details please see see www.ico.org.uk

FOR DETAILS ABOUT HOW WE MANAGE PERSONAL DATA IN RELATION TO RUNNING NEW BUSINESS CAMPAIGNS ON BEHALF OF OUR CLIENTS, PLEASE READ THE SECTION ON PERSONAL DATA HELD ON THE ALCHEMIS CRM DATABASE.

Suppliers, Ex-Suppliers and Potential Suppliers

What is personal data?
Personal data relates to a living individual who can be identified from that data.

Why do we need your Personal Data?
In order to operate as a business, Alchemis may need to collect, process and retain relevant necessary personal information from its clients. This will include holding some data about former suppliers for a period of time after we stop using their services, as well as certain relevant details from potential suppliers that may have approached or been approached by Alchemis for the purposes of operating our business.
For this purpose, Alchemis is defined as the Data Controller.
Alchemis may collect and securely store certain information such as the name, job title, business email and phone number, work address, etc of specific staff employed by its suppliers if they are involved in the administration of any work we do. We collect these details in order to complete essential tasks – for example to pay invoices, communicate with the suppliers about products and services we may buy from them, etc. We may also collect these details if they necessary by law.
Most staff at Alchemis Holdings will have access to these details, although some information may be restricted. For example, a supplier’s bank account details will only available to strictly necessary staff such as the Business Owners or the Finance Manager.
Essential third parties only, such as our Accountants, may have some access to certain personal details during the course of any work they carry out for Alchemis. For example, they may have access to the name and business email address for a member of staff at an Alchemis supplier whilst working on a shared software package to produce our accounts.
We will not share personal data with other third parties unless we are obliged to disclose personal data by law, or the disclosure is necessary for purposes of national security, taxation and criminal investigation, or we have your consent.

How do we collect this Personal Data?
Most of this personal data is provided directly by the supplier, but in some instances it may be provided from information provided on the supplier’s own website or via a third party such as Companies House, LinkedIn or a relevant B2B list or directory. Any data collected through a third party would be verified with the supplier by Alchemis and amended or removed as necessary.

How long do we keep your data for?
Alchemis will not retain your personal data for longer than is reasonably necessary. Data will be held within the timeframes currently set out by the Government or other such organisations who require this information to be held by Alchemis by law (eg HMRC).
If necessary we will retain data in order to resolve disputes, or contact you in relation to further products and services we may buy from you in the future.

Queries About Your Personal Information and Subject Access Requests
If you have any queries with regard to the above practices please speak to your Account Manager (for current suppliers) or contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PRIVACY POLICY (for ex-suppliers and potential suppliers) with a brief message outlining your query.
You have the right to see what personal data we hold about you. To obtain a copy of the personal information we hold about you, please email us at info@alchemis.co.uk with the subject heading SUBJECT ACCESS REQUEST.
You have the right to withdraw consent at any time to any of your personal data we may hold or process. To do this, please contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PERSONAL DATA and a brief message. Please note that this will be subject to any guidelines by the Government or other such organisations who require this data to be held by Alchemis by law (eg HMRC).
Alternatively you can also write to the Data Protection Officer, Alchemis Holdings Ltd, Flitcroft House, 114-116, Charing Cross Road, London WC2H 0JR.
If you feel any query you have has not been resolved you have the right to make a complaint to the Information Commissioners Office. For details please see see www.ico.org.uk

Personal Data Held On The Alchemis CRM Database
Alchemis owns and manages a CRM database which contains B2B information about companies that both Alchemis and our clients work with or could potentially work with. Within this database we hold certain relevant information which lists the names and job titles of certain relevant business decision makers within those companies. In some cases we also hold the business email address, direct line or business mobile phone number for those contacts. This database also contains ringfenced notes detailing conversations our staff have had with these decision makers on behalf of Alchemis or our clients.

How Do We Collect This Data?
This data is researched and collected through a range of sources such as:
From the website of the Company that the Data Subject works for
From online B2B platforms that the Data Subject has shared their information with (eg LinkedIn)
From information that is in the public domain (eg details held on Companies House)
From speaking to the Data Subject themselves (or an immediate colleague within their department) during the course of our research
From information purchased through reputable, GDPR compliant list brokers and subsequently verified by Alchemis staff.

What Basis Do We Have To Process This Data?
Alchemis carries out direct B2B marketing for ourselves and on behalf of our clients. The lawful basis we use for this processing is “Legitimate Interest” for “direct marketing”. This is covered in the GDPR. The ICO recommend that companies using this basis conduct a “Legitimate Interests Assessment” (LIA) and we have done this. Any of our clients that we share your details with may contact you to explain their own lawful basis.
Alchemis will only process and store any personal data if the data subject has given consent or if there is a clear legitimate interest to do so.

Queries About Your Personal Data, Your Right To Object and Subject Access Requests
You have the right to see what personal data we hold about you. To obtain a copy of the personal information we hold about you, please email us at info@alchemis.co.uk with the subject heading SUBJECT ACCESS REQUEST.
You have the right to withdraw consent at any time to any of your personal data we may hold or process. To do this, please contact the Data Protection Officer at info@alchemis.co.uk with the subject heading PERSONAL DATA and a brief message. Please note that this will be subject to any guidelines by the Government or other such organisations who require this data to be held by Alchemis by law (eg HMRC).
Alternatively you can also write to the Data Protection Officer, Alchemis Holdings Ltd, Flitcroft House, 114-116, Charing Cross Road, London WC2H 0JR.
If you feel any query you have has not been resolved you have the right to make a complaint to the Information Commissioners Office. For details please see see www.ico.org.uk

Who Has Access To This Information?
All Alchemis staff have access to the basic level of information (the name of the postholders we have within a company, their email address and the direct business contact number if available).
Our clients have access only to any personal data that has been collected specifically for them during the course of a campaign.
Alchemis may act as both Data Controller and Data Processor during the course of work carried out on behalf of our clients.

How Is This Data Stored?
All information within our database is stored on a secure server, hosted and managed by Amazon Web Services.
When we carry out New Business Campaigns on behalf of our clients we may export relevant data specifically collected on their behalf during the course of the campaign as an XL or CSV files to send to the client through our secure email system. We may also print relevant reports and hand these to the client at face to face meetings. In these circumstances, the client is also considered to be the Data Controller and should manage any data collected on their behalf accordingly.

Additional Safeguards
All calls made by Alchemis, either directly or on behalf of our clients, are screened against the Telephone Preference Service.
Alchemis operate comprehensive Do Not Approach filters to ensure that prospects who have asked not to be contacted by either Alchemis or on behalf of one of our clients are removed from any marketing list.
Any email sent to prospective clients will have a clear option to unsubscribe. Anybody that unsubscribes will be removed from any future marketing email correspondence from Alchemis.
Any paper documents that contain personal data (such as conversation reports we may have had with prospects from our database on behalf of our clients) are securely shredded on a cyclical basis and within a two-year time frame.

This privacy notice was last updated on 23rd April 2018. Alchemis will review this notice regularly and update any changes as necessary.

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