Privacy Policy

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This notice tells you who Apeiro Advisory & Business Solutions Limited are, what information we collect about you and what we do with it. 

Apeiro Advisory & Business Solutions Limited (“Apeiro”) is a company incorporated and registered in England and Wales (registered number 12941751) whose registered office address is at 41 Broughton Road, South Woodham Ferrers, Chelmsford, England, CM3 5YP.

Apeiro is referred throughout as “we”, “us”, “our” and “ours”. 

We enter into arrangements with individuals, partnerships and corporates (“Affiliates”) that enhance our offering to clients. 

We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice unless we inform you otherwise. To ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information that we might hold about you.

Our core business activity is consultancy and resourcing (“Services”) and we collect the personal data of the following types of people to allow us to undertake our business:

• Individuals looking for a role to work with us or who wish to engage with us as part of our Services (“Applicants”)
• Prospective and live Client, Hiring and Supplier contacts (“Business Contacts”)
• Our employees, consultants and temporary workers
• Visitors to our website

We may collect information about you in various ways.

• Information you provide us. You may provide us with information directly including your CV, information on a contact enquiry form, payroll related information, emailing or calling us. This will be how we collect most of the data about you that we process. We will not be able to assign you opportunities to work with Apeiro unless you provide such information to us.

• We collect personal information when: 

     You enquire about, or apply for, roles with Apeiro:

• Send us (or a third party sends us your CV or contact details with your consent) together with applications for opportunities with Apeiro. This includes information such as your title, name, address, email address and telephone number.
• Undertake background vetting as part of securing work with Apeiro. For example, information that is necessary to confirm your right to work in the UK, to complete disclosure & barring service checks and credit referencing.
• Register for payroll with Apeiro.
• Send us contact enquiry forms, emails or call us.
• Take part in market research and surveys (for example, satisfaction surveys).

     Provide information as a business contact or third-party supplier

• Contact details such as your title, name, business telephone number and business e-mail address.

• We may collect information automatically. 
  • If you visit our website it may automatically collects some information about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version and the pages on the site that you visit.
  • Our website may download "cookies" to your device. 
  • If you exchange emails, telephone conversations or other electronic communications with us then our information technology systems will record details of those conversations, sometimes including their content.
  • If you respond to surveys that we may send to customers from time to time about the services provided by Apeiro.
  • Our premises may have closed circuit TV systems for security and safety purposes. These may record you if you visit our premises.

• We may acquire information from third parties. This includes:
  • Referrals from your contacts and referrals from other firms with the intention of providing you with opportunities to work with Apeiro.
  • Fraud prevention, enforcement or government agencies used to prevent or detect fraud or provide details to us about criminal convictions or offences.
  • HM Treasury and other authorities in relation to regulatory issues.
  • Publicly available sources. For example, information on social media platforms such as Facebook and Twitter.

For what purposes do we use information about you, and on what legal basis?

We describe below the purposes for which we use personal information.

• Providing you with the service you have requested. We process your data to provide you with the service you have requested or otherwise engaged with us in respect of, for example: to apply and be eligible for opportunities to work with Apeiro and its clients, including completion of any background vetting required to secure engagement by Apeiro and its clients.
• Business and operational reasons. We process your information to otherwise operate, manage, develop and promote our business. For example, we need your personal information to be able to pay you for services provided to Apeiro and its clients.
• Comply with our legal and regulatory obligations and to defend legal claims. We may need to process your personal information to comply with our legal and regulatory obligations and to defend ourselves against legal claims, for example, to carry out sanctions, fraud and money laundering checks.
• To keep you updated about opportunities to work with Apeiro. We will use your personal data to keep you updated about the opportunities for working with Apeiro.
• Direct marketing. If you subscribe to Apeiro’s newsletters, articles, blogs and mailing lists for the purpose of receiving insights and updates on opportunities, where you let us know you would like to receive this material we will use your details in order to send you such information. If you tell us that you do not want to receive marketing information we will not use your information for marketing reasons. If we send you marketing emails you can also unsubscribe by contacting us (details below).
• Marketing and research. We may anonymise your personal information to process it for marketing and consumer research purposes.

The legal basis for our use of your information 

The legal basis for use of your information is one of the following:

• compliance with our legal obligations;
• the performance of a contract to which you are a party; or
• a legitimate business interest that is not overridden by your own interests in relation      to that data.

In other circumstances we will always ask for your consent before we process the information.

      Applicants

• Processing and responding to your contact enquiries made via the contact form on our website is in our legitimate interest to provide you with information about our business.
• To assess and process your application to work with us which is required for us to perform the contract with you, or to take steps to enter into a contract with you. This is necessary for our legitimate interests and to verify your suitability for our opportunities with Apeiro.
• To carry out checks on your right to work in the UK which is required for us to comply with our legal obligations.
• To carry out health checks – where necessary for the purposes of carrying out our employment obligations.
• To carry out Disclosure & Barring Service checks which may be necessary for the purposes of carrying out our employment obligations.

      Business contacts

• Processing and responding to your contact enquiries made via the contact form on our website is in our legitimate interest to provide you with information about our business.
• Your contact information to provide you with details on our services. This may include insights, technical information and/or marketing information. This is in pursuit of our legitimate interests to keep you informed about our services.

You have the right to withdraw your consent

In limited circumstances where you may have provided your consent processing your personal information for a specific purpose, including direct marketing, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing or via email using the contact details set out at the end of this privacy policy.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

Do we process your sensitive personal information?

No, in the normal course of our business we will not collect or process your sensitive personal information. In the event exceptions occur, then we take appropriate steps to safeguard your sensitive personal information.

Who do we share your information with, and for what purposes?

We may share personal information about you with the following kinds of third parties:

• Where this information is required for resourcing Apeiro engagements we may need to share information with Clients and Affiliates. You may also be required to provide personal information directly to our Clients and Affiliates so they can undertake vetting/background checks where required.
• To third party software and IT service providers who host our websites or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality, data privacy and security.
• To a person who takes over our business and assets, or relevant parts of them.
• To our professional advisers including lawyers, accountants and insurers.
• Regulators (e.g. the Financial Conduct Authority), government agencies (e.g. HMRC) and law enforcement or fraud prevention agencies, as well as our professional advisers.
• To competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in the applicable country or territory.

Where might information about you be sent?

When using information as described in this notice, information about you may be transferred either within or outside the United Kingdom where it was collected, including to a country or territory that may not have equivalent data protection standards. In all cases, the transfer will be:

• on the basis of a European Commission adequacy decision (or equivalent decision in the UK);
• subject to appropriate safeguards, for example the EU Model Contracts; or
• necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or for the conclusion or performance of a contract concluded in your interest between us and a third party.

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.

How do we protect information about you?

We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, misuse, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements. 

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. For example, we are sometimes legally required to retain information for tax and accounting purposes. After that, we will delete or anonymise it. 

We assess the time we retain information for different information based on the type and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purposes through other means.

      Applicants

• Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.
• Where your application for employment is unsuccessful, we will keep your personal information, such as your CV and application details, for 6 months. 

      Business contacts

      The time we keep your personal information depends on a range of factors, including:

• Where your personal information was collected in the course of us doing business together then we will keep your personal information for as long as this business continues. This includes where we have mutual commercial interests in holding your personal information with a view to future mutually beneficial opportunities unless you request your data to be erased.
• We will continue to provide you with communications with opportunities and insights until you confirm that you no longer wish to receive them.

What legal rights do you have in connection with your personal information?

You may have some or all or some of the following legal rights in respect of any personal information about you that we hold:

Request access to it (a data subject access request). You can obtain a copy of the personal information we hold about you.

Request us to correct it. You can have your information corrected where it is inaccurate or incomplete.

Request us to update it. You can have your information updated following a change in your circumstances

Request us to erase it. You can have your personal information deleted where:

• we have no reasonable basis for continuing to process your information.
• we use the information on the basis of your consent, and you withdraw your consent;
• we use the information on the basis of legitimate interest and we find that, following your request, we do not have an overriding interest in continuing to use it;
• the information was unlawfully obtained or used; or
• it is necessary to comply with a legal obligation

Request the restriction of processing of your personal information.  You can request that we suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party. For any such requests please contact our Data Protection Officer using the contact details set out at the end of this privacy policy.

Fee for access to your personal information. You will not need to pay a fee for access to your personal information however we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstance.

Who should you contact with questions?

The data controller is Apeiro Advisory & Business Solutions Ltd of 41 Broughton Road, South Woodham Ferrers, Chelmsford, Essex, CM3 5YP.

If you have any questions, or wish to exercise any of your rights, you can contact us via email at dpo@apeirosolutions.co.uk

The UK’s data protection authority is the Information Commissioner’s Office. You have a right to contact them with any questions or concerns (please see contact details below).

Right to complain

If you believe you have grounds to complain as to the processing of your personal information, then you may lodge a complaint with the UK Information Commissioner.

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 1625 545 700