The regulation relates to all sizes of organisation but larger organisations have to have a Data Protection Officer, but this does not apply to small organisations such as Careers-Action.
The Chief Executive through the Operations Director is responsible for the safety of data and protection of persons personal information. Members should not discuss the personal circumstances and information of other members.
BASIS FOR DATA PROCESSING
Careers-Action will process data on the basis of the agreement or contract with its members (Article 6(1b)). The application form that member will complete will tell them the information we will retain in our data base and the reason for us holding that information including how we will process it. We will be processing information we held when we send out emails or searching for job information for the members concerned. Normally Careers-Action will send out two emails a week. One of these will be a jobs email containing information on job vacancies, courses and business opportunities with related information. The other email will be about the training session due that week and another other news that might be relevant to the membership.
If any other information is required for any reason then consent will be required to process any extra data.
RIGHT TO BE INFORMED
Each member has the right to be informed about the information Careers-Action holds and how it processes that information. All members will receive a copy of this document and Careers-Action will inform members when items within this change.
RIGHT TO ACCESS YOUR DATA
All members have the right to access the information we hold on them. In order to access the information that Careers-Action holds on them members need to contact either the Operations Officer or if not available the Chief Executive. Applications can be made verbally, on email or in writing. The information will be provided within four weeks of the request.
RIGHT OF RECTIFICATION
If the member believes Careers-Action holds incorrect information about them they can request that information is changed. The can make such a request in writing or by email and the information will be corrected in four weeks of receipt of the new information.
RIGHT TO DATA PORTABILITY
If a member requests we transfer the information we hold on them to another service Careers-Action will transfer that information within four weeks of a written request by letter or email to do so.
RIGHT TO RESTRICT PROCESSING
If a member requests their information to be restricted for a specific purpose then Careers-Action will action that within four weeks of receipt of a written request.
RIGHT TO BE FORGOTTEN
Every member has the right to be forgotten although they must understand that if this is activated they will not be able to gain the information provided in the emails we distribute. The emails Careers-Action will send out will have the option for members to self-forget themselves (activate a key to delete themselves from the database).
If Careers-Action has a data breach, this will be reported to the Information Commissioners Office within two weeks of finding out a breach has occurred. Data breaches will include unauthorised access to the data or loss of data such as a memory stick being lost or a computer being hacked. In the case of theft of equipment, the Police will also be informed.
Careers-Action officers will ensure that measure are in place to protect their computers against hacking and theft of data or equipment. Access to the computers must be on password and suitable protective software will be installed for internet use.
YOUR CONTROLS & PRIVACY RIGHTS
We believe that you should have control of your information. You can review or edit your account information, including your marketing preferences, location data, mobile choices, advertising settings and search history, and account deletion controls by visiting unsubscribing. Some of our Services may provide additional controls.
In many cases where we process your information, you may also have a right to restrict or limit the ways in which we use your information. In certain circumstances, such as those described in the ‘legitimate interests’ section above, you also have the right to object to the processing of your information by us.
You can also request the rectification of your information by us. You can request that we delete your information, and Careers-Action will carry out this request unless certain exceptional reasons arise permitting Careers-Action to keep certain information about you.
You also have the right to obtain a copy of your information in an easily accessible format. In certain circumstances, you can also request that we transfer some of your information to third parties. Careers-Action will help you exercise these important rights.
You have the right to withdraw your consent to our processing of your information and your use of our Services at any time. Similar to the way in which you can give consent by interacting with our Services, you can also withdraw your consent through our Services. You can choose to delete your Careers-Action membership via your account settings and we will delete your information.
INFORMATION COLLECTION AND USE – GENERAL
Certain categories of information collected by Careers-Action are necessary to use our Services, such as the information you must provide when registering for some Services. We may collect and combine information when you interact with Careers-Action Services including information outlined below
- Information that you provide to us. We collect the information you provide to us in order to enable us to operate and provide our Services, including:
- When you create a membership account with Careers-Action. (please note that, when you use our Services, we may recognise you or your devices even if you are not signed in to our Services.)
- Careers-Action may use device IDs, cookies and other signals, including information obtained from third parties, to associate accounts and/or devices with you.
- When you use our Services to communicate with others or post, upload or store content (such as comments, photos, voice inputs, videos, emails, messaging services and attachments).
- When you otherwise use our Services, such as view the website content that we make available, perform search queries or install any Careers-Action software such as plug-ins.
- When you sign up for paid Services, use Services that require your financial information or complete transactions with us or our business partners, we may collect your payment and billing information in order to provide you with those paid Services. We may remember the payment information that you entered during a prior purchase for paid Services and provide you with the option to use that payment information during the purchase of a new product.
- Device information. We collect information from your devices (computers, mobile phones, tablets, etc.) in order to provide you with our Services, including information about how you interact with our Services and those of our third-party partners and information that allows us to recognize and associate your activity across devices and Services. This information includes device-specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings and software data.
- Location information. We collect location information from a variety of sources. You can learn more about and manage your location permissions on our Locations page or by visiting the location settings tool on your devices.
- Information from cookies and other technologies.
- We collect information when you access content, advertising, sites, interactive widgets, applications and other products (both on and off our Services) where Careers-Action data collection technologies (such as web beacons, development tools, cookies and other technologies, etc.) are present. These data collection technologies allow us to understand your activity on and off our Services and to collect and store information when you interact with Services we offer to partners.
- This information includes the kind of content or ads served, viewed or clicked on; the frequency and duration of your activities; the sites or apps you used before accessing our Services and where you went next; whether you engaged with specific content or ads; and whether you went on to visit an advertiser's website, downloaded an advertiser’s app, purchased a product or service advertised or took other actions.
- Information from others. We collect information about you when we receive it from other users, third parties and affiliates, such as:
- When you connect your account to third-party services or sign in using a third-party partner (such as Facebook or Twitter).
- From publicly available sources.
- From advertisers about your experiences or interactions with their offerings.
- When we obtain information from third parties or other companies, such as those that use our Services. This may include your activity on other sites and apps as well as information that those third parties provide to you or us.
HOW WE USE THIS INFORMATION
We mainly rely on three separate bases to lawfully process your information. First, we need to process your information in certain ways to provide our Services to you, in accordance with our Terms of Service. This processing is necessary to perform the contract between you and us, and our membership rules make it clear that processing of your information for the purposes of personalized content is a necessary part of the Services we provide. Second, where you have given us consent to use your information in certain ways, we will rely on your consent. Third, as described in more detail below, in certain cases, we may process your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests. Occasionally, Careers-Action may rely on other legal bases to process your information such as to protect a user’s vital interests (such as where there is a risk of imminent harm) or to comply with a legal obligation.
In order to deliver, personalise and improve our Services, we combine and use the information that we have about you (including information we receive on and off our Services) to understand how you use and interact with our Services and the people or things that you’re connected to and interested in. As membership to Careers-Action lower levels is free, occasionally Careers-Action may allow adverts to run on our systems to help raise the money to operate the service. We may also use the information we have about you in the following ways and for the following purposes:
- To provide, maintain, improve and develop relevant features, content and Services.
- To analyse your content and other information (including incoming and outgoing emails, instant messages, posts photos, attachments and other communications) in order to keep our Services safe and secure and to assist us in making the content, Services and ads we provide to you more personalised. You can review and control certain types of information tied to your Careers-Account account by using Privacy Controls.
- To fulfil your requests and when authorised by you.
- To help advertisers and publishers connect to offer relevant advertising in their apps and websites.
- To match and serve targeted advertising (across devices and both on and off our Services) and provide targeted advertising based on your device activity, inferred interests and location information.
- To contact you with information about your account or with marketing messages, which you can also control.
- To associate your activity across our Services and your different devices as well as associate any accounts you may use across Careers-Action Services together. We may associate activity and accounts under a single user ID.
- To carry out or support promotions.
- To conduct research and support innovation.
- To create analytics and reports for external parties, including partners, publishers, advertisers, apps, third parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads and information on user experiences. These analytics and reports may include aggregate or pseudonymised information, but do not include any information relating to an identified or identifiable user.
- To provide location-based Services, advertising, search results and other content consistent with your location settings.
- To combine information that we have about you with information that we obtain from business partners or other companies, such as your activities on other sites and apps in order to ensure that the ads, Services and content we provide to you are more suited to your interests. .
- To detect and defend against fraudulent, abusive or unlawful activity and to keep our Services safe and secure.
We provide you with controls to manage your experience with us. For example, you can review or edit your account information, manage your marketing preferences or opt out of targeted ads. While personalized ads are necessary for the purposes of our legitimate interests and are a necessary part of our agreement with you, we offer you the ability to object to certain personalized ads through your choices to opt out of certain targeted ads. If you object through this opt-out, you will continue to see ads, but they may not be as relevant or useful to you.
HOW WE SHARE THIS INFORMATION
- With your consent. We will share information with companies, organisations or individuals outside of Careers-Action when we have your consent.
- Within Careers-Action. Information may also be shared within Careers-Action, including with other Careers-Action trainers and affiliates. Careers-Action affiliates may use the information in a manner consistent with their privacy policies.
- With partners. We may share your information with non-affiliated companies who are:
- Trusted partners. We provide user information to trusted partners who work on behalf of Careers-Action based on our directions and in compliance with appropriate confidentiality measures. Learn more.
- Advertising, analytics and business partners (limited to non-personally identifiable information). We may share aggregated or pseudonymous information (including demographic information) with partners, such as publishers, advertisers, measurement analytics, apps or other companies. For example, we may tell an advertiser how its ads performed or report how many people installed an app after seeing a promotion. We do not share information that personally identifies you (personally identifiable information includes your name or email address) with these partners, such as publishers, advertisers, measurement analytics, apps or other companies.
When you use third-party apps, websites or other products integrated with our Services, they may collect information about your activities subject to their own terms and privacy policies.
- For legal purposes. We may access, preserve and disclose information to investigate, prevent or take action in connection with: (i) legal processes, and legal and governmental agency requests; (ii) enforcement of the Terms; (iii) claims that any content violates the rights of third parties; (iv) requests for customer service; (v) technical issues; (v) protecting the rights, property or personal safety of Oath, its users or the public; (vi) establishing or exercising our legal rights or defending against legal claims; or (vii) as otherwise required by law.
- This may include responding to lawful governmental requests. Learn more about how we evaluate and respond to these requests.
- New ownership. If the ownership or control of all or part of Careers-Action or a specific Service changes as a result of a merger, acquisition or sale of assets, we may transfer your information to the new provider.
DETAILS FOR SPECIFIC PRODUCTS AND SERVICES
Additional privacy practices for certain Careers-Action Services are included here.
INFORMATION SECURITY AND DATA RETENTION
Careers-Action has technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information that we collect or store.
Careers-Action may also use your information for safety and security purposes, including the sharing of your information for such purposes as is necessary to pursue our and your legitimate interests of ensuring the security of our Services, including enhancing users’ protection against harassment, IP infringement, spam, and crime and security risks of all types.
You have the right to object to any of this processing.
DATA PROCESSING AND TRANSFERS
Careers-Action only operates in the Milton Keynes area at the moment and so will not transfer your data outside the UK without your knowledge and permission.
OTHER IMPORTANT INFORMATION