1. Who this Privacy Notice applies to
At AkinovA Group (AkinovA) we take your privacy seriously. AkinovA is committed to protecting the privacy of our clients, contacts and users of our website. This Privacy Notice states our policy and practices regarding the collection and use of information when being employed by AkinovA. When we refer to AkinovA, “we”, “us” or “our” we mean our entire group, including our divisions, subsidiaries and affiliates from time to time.
We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, is only used for the purposes set out in this Notice.
Through this Privacy Notice we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR“) (where applicable), GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR“) and the Data Protection Act 2018.
For the purpose of this Privacy Notice the controller of personal data is AkinovA Ltd. and our contact details are set out in the Contact section at the end of this Privacy Notice. References in this Privacy Notice to our Group of companies refers to AkinovA Ltd as parent company of the Group, and to other trading divisions, affiliates and subsidiaries from time to time of AkinovA Ltd.
Right to Object: You have a legal right to object at any time to:
(i) use of your personal information for direct marketing purposes; and
(ii) processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
See section 9 below for further details.
3. The Information we may collect
- Passport Number
- Driving Licence Number
- Pay records and National Insurance Number
- Addresses for last 5 years
- Employment history for last 5 years
- Email address
- Phone Number
- Basic DBS check
- Bank account details
- Employment contract
- Recruitment records including you application form and any references received
- Date of birth, martial/civil partnership status
- Details of dependents and next of kin
- Holiday, sickness and other absence records
- Performance records
- Records and information relating to benefits such as pension and health insurance
- Information about your professional qualifications
- Information relating to your use of email, the internet and our telephone system
- Details of any complaints or concerns raised by you
- Images of you that are captured on CCTV systems that are in operation inside and outside of the office building (whether operated by AkinovA, on our behalf or to which we have access
- Information collected in relation to use of your access card, fob or other token
4. How we use your Personal Information
We will hold, use and disclose your personally identifiable information for our legitimate business purposes including:
- Complete employment reference checks
- Complete DBS checks
- Complete ID verification
- To comply with regulatory requirements of the BMA and UK legal requirements
- Perform payroll
5. The Legal Basis for Processing your Personal Information
Processing is (a) for the performance of a contract, (b) necessary for the purposes of legitimate interests of AkinovA and (c) for compliance with a legal obligation.
6. How we share your Personal Information
We may disclose your personally identifiable information with other parties. Details of those parties are set out below along with the reasons for sharing it.
6.1 Other Companies within our Group
When you disclose your personal information to us we may share it with other companies in our Group of companies.
We will share your personal information as above for any or all of the following purposes:
- To work with other affiliates and subsidiaries within our Group of companies
As we grow all of the subsidiaries and affiliates in our Group of companies will enter into the standard contractual clauses approved by the ICO or as the case may be the European Commission, to safeguard the personal information which is transferred across our Group of companies to and from the European Economic Area.
6.2 Third Parties
We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, or which are required in order to enable us to maintain our records. Among these are:
We require minimum standards of confidentiality and data protection from such third parties. To the extent that any personal information is provided to third parties outside the UK, or who will access the information from outside the UK, we will ensure that approved safeguards are in place, such as adequacy decisions or the approved standard contractual clauses.
6.3 Regulatory and Law Enforcement Agencies
We may disclose your personal information if required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if it is permitted under UK GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
6.4 New business owners
If we or our business are merged with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, we will notify you of such event.
7. Sending data outside of the UK and/or European Economic Area
We will only send your data outside of the UK and/or European Economic Area (“EEA”) in the following circumstances:
- To staff members of the AkinovA Group in Bermuda and elsewhere
- To supplier data centres where AkinovA are not able to dictate what data centres are used
- Where required or requested by law, regulation, by a court of competent jurisdiction or by any regulatory body or governmental authority
We may also store your personal data via third party web-based applications, cloud services or web-based storage providers, some of whom may be based outside of the EEA and/or the UK.
In the event that your Personal Data is sent outside the UK and/or European Economic Area (a “Restricted Transfer”) in one of the above circumstances, and such transfer is not necessary for the performance of a contract or in relation to a legal or regulatory process, we will ensure that at least one of the following safeguards are in place to protect your data:
- The Restricted Transfer is to a non-UK/EEA country with equivalent data protection and privacy laws to the UK/EEA (as applicable);
- The entity receiving the Personal Data commits to maintaining sufficient levels of security and protection with respect to its handling of the Personal Data.
8. How long we will hold your information
We will retain your personal information for 6 years following the end of your employment or engagement with AkinovA. We may retain your data longer for one of the following reasons:
- We are required to retain the data for a longer period of time in order to comply with a legal or regulatory obligation
- We are unable or it is impractical, for technical or operational reasons, to delete the data.
If we retain your Personal Data for a longer period as described above, we will ensure that we continue to comply with the provisions of the GDPR with respect to securing and protecting your Personal Data.
9. Your rights relating to Information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
9.1 Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the UK GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
9.2 Right of Correction or Completion
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed.
9.3 Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
9.4 Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
9.5 Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation.
The above right exists only in respect of personal information that:
- you have provided to us previously; and
- is processed by us using automated means.
Whilst we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.
If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:
Telephone: 0303 123 11113
Post: Information Commissioner’s Office
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.
We will comply with the UK GDPR when processing your Personal Data. We have put in place measures to ensure the security of the information we collect and store about you and will use our reasonable endeavours to protect your personal data from unauthorised disclosure and/or access including through the use of generally accepted standards of technology and operations security measures, but these cannot guarantee the security of any data which is collected and stored.
We are not responsible for, and have no control over, information that is submitted or collected by these third parties and you should consult their privacy policies.
12. Changes to our Privacy Notice
This Privacy Notice is subject to change from time to time and the latest version of the notice can be obtained at https://akinova.com/staff-privacy-notice/.
13. Contact Us
If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. When you contact us, we will ask you to verify your identity.
Post: AkinovA Ltd., 15 Bishopsgate, London, EC2N 3AR
Our registered office is at:
15 Bishopsgate, London, EC2N 3AR