Data Protection Statement

for Newt Idea Ltd

Introduction

If you are a Client, Subcontractor, or a business contact of ours, we will hold your personal data for business purposes. Your personal data is data which by itself or with other data available to us can be used to identify you. We are Newt Idea Ltd, the data controller. This data protection statement sets out how we’ll use your personal data. You can contact our Data Protection Officer at 4 Wellesley Terrace, London, N1 7NA if you have any questions.

1. CLIENT SECTION

1.1 The types of personal data we collect and use

Whether or not you become a Client we’ll use your personal data for the reasons set out below. If you become a Client we will use it to manage the contract or service you’ve signed up for. We’ll collect most of this directly during the contract setup process. The personal data we use may include:

Full name and personal details including contact information (eg office address, email address, work and mobile telephone numbers);
Records of products and services you’ve obtained or requested

1.2 Using your personal data: the legal basis and purposes

1.2.1 We’ll process your personal data:

As necessary to perform our contract with you
To take steps at your request prior to entering into it;
To decide whether to enter in to it;
To manage and perform that contract;
To update our records;
To trace your whereabouts to contact you

1.2.2 As necessary for our own legitimate interests or those of other persons and organisations

For good governance, and for managing and auditing our business operations;
To monitor emails or other communications;
For market research, analysis and developing statistics;
To send you marketing communications

1.2.3 As necessary to comply with a legal obligation, eg

When you exercise your rights under data protection law and make requests;
For compliance with legal requirements and related disclosures;
For establishment and defence of legal rights;
For activities relating to the prevention, detection and investigation of crime;
To monitor emails, calls, and other communications;

1.2.4 Based on your consent, eg:

When you request us to disclose your personal data to other people or organisations such as another supplier, or otherwise agree to disclosures; and
To send you marketing communications where we’ve asked for your consent to do so.

You’re free at any time to change your mind and withdraw your consent. The consequence might be that we can’t do certain things for you.

1.3 Sharing of your personal data

Subject to applicable data protection law we may share your personal data with:

Subcontractors and other persons who help us provide our products and services;
Companies and other persons providing services to us;
Our legal and other professional advisors;
Fraud prevention agencies;
Courts, to comply with legal requirements, and for the administration of justice;
In an emergency or to otherwise protect your vital interests;
To protect the security or integrity of our business operations;
If we restructure or sell our business or its assets or have a merger or re-organisation;
Anyone else where we have your consent or as required by law

1.4 Your marketing preferences and related searches

We’ll use your address, phone numbers, email address and social media (eg Linked In, Google and message facilities in other platforms) to contact you according to your preferences. You can change your preferences or unsubscribe at any time by contacting us. In the case of social media messages you can manage your social media preferences via that social media platform.

If you don’t want information on other products and services or to be included in market research, and you haven’t told us before, you can let us know by sending your details as shown below to Newt Idea, 4 Wellesley Terrace, London, N1 7NA or by calling us on 020 3515 1030.

Your forename and surname
Email address

1.5 Retention periods

We’ll retain your personal data as long as necessary to deal with your queries. We’ll retain your personal data after your account or service has been closed or has otherwise come to an end based on our legal requirements.

2. SUBCONTRACTOR SECTION

2.1 The types of personal data we collect and use

Whether or not you become a Subcontractor we’ll use your personal data for the reasons set out below. If you become a Subcontractor we will use it to manage the contract you’ve signed with us. We’ll collect most of this directly during the interview and contract setup process. The personal data we use may include:

Full name and personal details including contact information (eg office address, email address, work and mobile telephone numbers)
Company and VAT details
CV, job title, educational background and work history
Portfolios and work examples
Financial, pay and bank details
Nationality
Availability dates and work preferences

2.2 Using your personal data: the legal basis and purposes

We’ll process your personal data:
2.2.1 As necessary to perform our contract with you

To decide whether to enter into a contract with you;
To manage and perform that contract;
To update our records;
To trace your whereabouts to contact you

2.2.2 As necessary for our own legitimate interests or those of other persons and organisations

To decide whether a potential role or project may be relevant to you;
To keep a record of your availability dates;
To monitor emails or other communications;
For market research, analysis and developing statistics;
For good governance, and for managing and auditing our business operations;
To investigate any complaints

2.2.3 As necessary to comply with a legal obligation

When you exercise your rights under data protection law and make requests;
For compliance with legal requirements and related disclosures;
For establishment and defence of legal rights;
For activities relating to the prevention, detection and investigation of crime;
To verify your identity;
To monitor emails, calls, and other communications;

2.2.4 Based on your consent, eg:

When you request us to disclose your personal data to other people or organisations such as another supplier, or otherwise agree to disclosures; and
To send you role and project opportunity communications where we’ve asked for your consent to do so.

You’re free at any time to change your mind and withdraw your consent. The consequence might be that we can’t do certain things for you.

2.3 Sharing of your personal data

Subject to applicable data protection law we may share your personal data with:

Subcontractors and other persons who help us provide our products and services;
Companies and other persons who may have an open role or project that may be of interest to you;
Our legal and other professional advisors;
Fraud prevention agencies;
Courts, to comply with legal requirements, and for the administration of justice;
In an emergency or to otherwise protect your vital interests;
To protect the security or integrity of our business operations;
If we restructure or sell our business or its assets or have a merger or re-organisation;
Anyone else where we have your consent or as required by law

2.4 Your communication preferences and related searches

We’’ll use your address, phone numbers, email address and social media (eg Linked In, Google and message facilities in other platforms) to contact you according to your preferences. You can change your preferences or unsubscribe at any time by contacting us. In the case of social media messages you can manage your social media preferences via that social media platform.

If you don’t want information on role or project opportunities, or to be included in market research, and you haven’t told us before, you can let us know by sending your details as shown below to Newt Idea, 4 Wellesley Terrace, London, N1 7NA or by calling us on 020 3515 1030.

Your forename and surname
Email address

2.5 Retention periods

We’ll retain your personal data as long as necessary to deal with your queries. We’ll retain your personal data after your contract has concluded or has otherwise come to an end based on our legal requirements.

3. BUSINESS CONTACTS SECTION eg suppliers and partners

3.1 The types of personal data we collect and use

We’ll use your personal data for the reasons set out below. We’ll collect most of this directly during the course of our dealings with you. The personal data we use may include:

Full name and personal details including contact information (eg office address, email address, work and mobile telephone numbers)
Company and VAT details

3.2 Using your personal data: the legal basis and purposes

We’ll process your personal data:

3.2.1 As necessary to perform our contract with you (if applicable)

To decide whether to enter into a contract with you;
To manage and perform that contract;
To update our records;
To trace your whereabouts to contact you

3.2.2 As necessary for our own legitimate interests or those of other persons and organisations

To monitor emails or other communications;
For good governance, and for managing and auditing our business operations;

3.2.3 As necessary to comply with a legal obligation

When you exercise your rights under data protection law and make requests;
For compliance with legal requirements and related disclosures;
For establishment and defence of legal rights;
For activities relating to the prevention, detection and investigation of crime;
To monitor emails, calls, and other communications;

3.2.4 Based on your consent, eg:

When you request us to disclose your personal data to other people or organisations such as another supplier or partner, or otherwise agree to disclosures;

You’re free at any time to change your mind and withdraw your consent. The consequence might be that we can’t do certain things for you.

3.3 Sharing of your personal data

Subject to applicable data protection law we may share your personal data with:

Subcontractors and other persons who help us provide our products and services;
Companies and other persons providing services to us;
Our legal and other professional advisors;
Fraud prevention agencies;
Courts, to comply with legal requirements, and for the administration of justice;
In an emergency or to otherwise protect your vital interests;
To protect the security or integrity of our business operations;
If we restructure or sell our business or its assets or have a merger or re-organisation;
Anyone else where we have your consent or as required by law

3.4 Your communication preferences and related searches

If you don’t want us to contact you, and you haven’t told us before, you can let us know by sending your details as shown below to Newt Idea, 4 Wellesley Terrace, London, N1 7NA or by calling us on 020 3515 1030.

Your forename and surname
Email address

3.5 Retention periods

4. GENERAL SECTION – applies to everyone – Clients, Subcontractors, and business contacts

4.1 Monitoring of communications

Subject to applicable laws, we’ll record your emails, text messages, social media messages (eg, Linked In messages) and other communications in relation to your dealings with us. We’ll do this so that we can deliver a good service to you, for self regulatory practices, crime prevention and detection, to protect the security of our communications systems and procedures, for quality control and staff training and when we need to see a record of what’s been said.

4.2 International transfers

Your personal data may be transferred outside the UK and the European Economic Area. This will only happen where the organisation receiving the personal data has provided appropriate safeguards.

4.3 Your rights under applicable data protection law

Your rights are as follows (noting that these rights don’t apply in all circumstances and that data portability is only relevant from May 2018):

The right to be informed about our processing of your personal data;
The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
The right to object to processing of your personal data;
The right to restrict processing of your personal data;
The right to have your personal data erased (the “right to be forgotten”);
The right to request access to your personal data and information about how we process it;
The right to move, copy or transfer your personal data

You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law: ico.org.uk.

For more details on all the above you can contact our Data Protection Officer.

4.4 Data anonymisation and aggregation

Your personal data may be converted into statistical or aggregated data which can’t be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.