Privacy Policy

Introduction

Welcome to the SafeSupplier Registration, Supplier, Client and Internal Portal (“the Portal”) privacy notice.

The Portal is managed and owned by Alcumus SafeContractor Limited (“SafeSupplier”, “we”, “us”, “our”) on behalf of our customer (“Customer”) in accordance with the contract for services we have in place with our Customer to provide supplier verification services. As a user, you may be our Customer or someone who is employed, engaged or authorised by our Customer to use the Portal.

As a user of the Portal, SafeSupplier respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit the Portal, and tells you about your legal privacy rights.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of the Portal, including any data you may provide through the Portal or provide to us to upload to the Portal.

The Portal is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Contact details

We are Alcumus SafeContractor Limited (Company Number 07618138), with our registered office at Axys House, Heol Crochendy, Parc Nantgarw, Cardiff, Wales, CF15 7TW. We are directly owned by Alcumus Holdings Limited (Company Number 06955372), and our ultimate parent company is Alcumus Group Limited (Company Number 09793309), both of the same registered office.

We have appointed a voluntary data protection officer (DPO) who is responsible for data protection matters within our business. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Karl Mrosek, on [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to work with you to deal with your concerns before you approach the ICO so please contact us in the first instance in the case of any issue.

Changes to the privacy notice and your duty to inform us of changes

This privacy notice was created on 24 November 2021. This is the first version of this privacy notice. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Portal contains links to our main company websites at www.alcumus.com and www.safecontractor.com. The Supplier Portal contains a link to the third party software platform used to deliver the questionnaire which we ask Suppliers to complete.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and/or your employees, including:

• Identity Data includes first name, maiden name, last name, username, and title (including where such details are included on any training or qualification certificate or documentation), data revealed by credit checks we undertake including financial stability and credit worthiness and data in relation to criminal records and data revealed by a check with the Disclosure and Barring Service.

• Contact Data includes billing and operational address(es), email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Portal.

• Usage Data includes information about how you use the Portal.

• Marketing and Communications Data includes your marketing and communication preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as demographic data for the purposes of linking suppliers to clients. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Portal feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Information you upload to the Portal

We provide access to the Portal on the basis of the fact that you are one of the following: (a) a Customer; (b) an employee of a Customer; (c) an employee of a third party to whom authority for use of the Portal has been delegated by a Customer; (d) a supplier working with either of those parties; or (e) an employee of a supplier who has been suitably authorised.

In relation to any personal data that you upload or record to the Portal (e.g. relating to Customer employees), our Customer is the data controller in respect of such personal data and this means that it/he/she remains primarily responsible for such personal data.

We process this personal data on behalf of our Customer in order to perform the services for our Customer and provide access to the Portal to you and other authorised users. The precise purpose for which the personal data is processed will be determined by the scope and specification of our terms of business with our Customer, and by any applicable laws.

It is always our Customer’s obligation to ensure that the data subjects of the personal data you (or any authorised user) upload to the Portal understand that their personal data will be processed by us in accordance with our contract with our Customer.

Information we upload to the Portal

There may be instances where we upload personal data to the Portal on your behalf or on our Customer’s behalf. We will act as data processor in relation to this personal data, and we will always act in accordance with this privacy notice.

If you fail to provide personal data

If you fail to provide personal data when requested, we may not be able to perform the contract we have or are trying to enter into with our Customer (e.g. to provide our Customer with our services). We will notify our Customer if this is the case.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services or complete an application for verification;

• create an account on the Portal;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us some feedback.

Automated technologies or interactions. As you interact with the Portal, 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.

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 analytics providers, such as Google, based outside the UK or EU.

• Identity Data and Contact Data from our anchor clients in respect of their supplier base.

• Identity Data and Contact Data from publicly availably sources such as Companies House, the HSE website, Gas Safe website, which are all based inside the UK and/or EU. Product Data, Identity Data and Contact Data from our trusted third parties where you have engaged with a third party product or service.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• 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.

• Where we need to comply with a legal or regulatory obligation.

• Where we have your consent.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing and Opt Out

We may from time to time undertake marketing, promotions or competitions via the Portal or via other means. You will be able to opt by opting out as part of your registration or by contacting us. You may also contact our DPO at [email protected]. Where you opt out of receiving these marketing messages, this opt out will not apply to contact relating to your use of the Portal, service messages or service experience communications.

Change of purpose

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. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Other companies in the Alcumus group of companies acting as joint controllers or processors and which provide IT, finance and/or system administration services.

• External third parties including:

  • UK-based service providers acting as processors who provide IT and system administration services (specifically Amazon Web Services, Microsoft Azure (Microsoft Ireland Operations Limited, Stripe Payments Europe Limited and Credas Technologies Limited).

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide legal, insurance and accounting services.

  • HMRC, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

  • Credit Reference Agencies such as Experian. Alcumus may undertake a credit reference check on its Customer via a third-party supplier as detailed below, and may share details of the Customer’s payment performance with such third-party supplier. This may impact the Customer’s credit score if it does not make payment within the agreed payment terms set out in this Contract. In the case of suppliers who are limited companies, limited liability partnerships or public limited companies, Alcumus may undertake a credit reference check via a third party supplier. The credit reference check shall allow Alcumus to obtain the following information:

  • public data on the supplier’s credit behaviour;

  • information on the conduct of the supplier’s credit accounts;

  • information on the financial stability and credit worthiness of the supplier.

In the case of suppliers who are sole traders and partnerships, a non-limited business risk report may be obtained from a third party supplier and/or a financial assessment may be completed by Alcumus. In accepting Alcumus’ terms and conditions, the supplier authorises Alcumus to undertake the financial assessment and credit reference checks outlined above.

• Third parties to whom we may choose to sell or merge parts of our business. 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.

• Third party anchor clients of SafeSupplier who may wish to purchase services via a supplier are able to access supplier information (including in some circumstances, Personal Data) via the Portal. Levels of personal data are limited in nature, restricted and redacted where appropriate. At present, the types of documents made available to anchor clients include: (i) risk assessments (ii) H&S policies; (iii) BS EN ISO certificates; (iv) H&S, Environmental and Quality management systems; (v) written references; (vi) ethical purchasing policy; (vii) various policies including but not limited to equality and diversity policy, modern slavery policy, safeguarding policy, anti-bribery policy, information security policy, GDPR policy and business continuity policy; (viii) criminal record details and credit check results; and (ix) insurance details. These documents may contain employee names, job titles and contact details (including email or postal addresses). Checks are undertaken by SafeSupplier to ensure that the documents shared do not contain extensive or unnecessary personal data in excess of the types and categories of personal data outlined above.

• Our telephony system and support service provider (currently Capita plc). The service includes the provision of telephone support, delivered via our network.

• Third party trusted partners we work closely with and will sometimes share information with them about you so that they can send you information about any of their products and services you may be interested in, or any promotions they are running. SafeSupplier’s current partners are set out below. If you would like more information about the ways in which they process personal data please refer to their privacy policies (as provided below):

  • Trade point;

  • Kerry London; and

  • Our group companies.

• Any other third party that you (or an authorised user) or our Customer may expressly instruct us to share personal data with.

6. Data Security

SafeSupplier is ISO 27001 certified and 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. We limit access to your personal data to those employees, contractors and suppliers and other third parties who have a business need to know. They are subject to a duty of confidentiality. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. International transfers

We do not transfer your personal data outside the UK or the European Economic Area (EEA).

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of performing our contract with you, 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 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.

Details of retention periods for your personal data are available on request by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, training or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have legal rights in relation to your personal data, including:

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.

Request correction of your personal data. 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.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object to processing (see below); (c) where we may have processed your information unlawfully; or (d) 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.

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.

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.

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.

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.

Request us not to use your personal data for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

No fee usually required 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.

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 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 contact you to ask you for further information in relation to your request to speed up our response.

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 if we require more time to respond to your request.

If you are not satisfied with our response to your request, you are able to raise a complaint with the ICO.

If you wish to exercise any of the rights set out in this policy, please contact us.