General Data Protection Regulations

PRIVACY.
How your personal information is used by Arena Personnel Ltd
Last updated March 2018.

Your information will be held by Arena Personnel Ltd, “Arena”
How we use your personal information:-

This privacy notice is to let you know how Arena promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a Client/candidate/supplier, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise
We promise:

• To keep your data safe and private.
• Not to sell your data.
• To give you ways to manage and review your marketing choices at any time.

Data Protection law changes on 25 May 2018

More information about your identity
Proving your identity

Who we are:- Arena Personnel Ltd is made up of one legal entity. You can find out more about us at www.arena-group.co.uk If you have any questions, or want more details about how we use your personal information, you can call us on 01462 481005.

How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Arena. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What we use your personal information for
Our reasons
Our legitimate interests

• To manage our relationship with you or your business.
• To develop new ways to meet our client/candidate/ supplier needs and to grow our business.
• To develop and carry out marketing activities.
• To study how our  client/candidate/ supplier use services from us and other organisations.
• To provide advice or guidance about our services. • Your consent.
• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty. • Keeping our records up to date, working out which of our services may interest you and telling you about them.
• Developing services, and what we charge for them.
• Defining types of client/candidate/ supplier for new services.
• Seeking your consent when we need it to contact you.
• Being efficient about how we fulfil our legal duties.
• To develop and manage our services.
• To manage how we work with other companies that provide services to us and our customers. • Fulfilling contracts.
• Our legitimate interests.
• Our legal duty. • Developing products and services, and what we charge for them.
• Defining types of client/candidate/ supplier for new services.
• Being efficient about how we fulfil our legal and contractual duties.
• To deliver our services.
• To make and manage client/candidate/ supplier payments.
• To collect and recover money that is owed to us.
• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty. • Being efficient about how we fulfil our legal and contractual duties.
• Complying with regulations that apply to us.
• To manage risk for us and our client/candidate/ supplier .
• To obey laws and regulations that apply to us.
• To respond to complaints and seek to resolve them. • Fulfilling contracts.
• Our legitimate interests.
• Our legal duty. • Complying with regulations that apply to us.
• Being efficient about how we fulfil our legal and contractual duties.
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, and audit. • Our legitimate interests.
• Our legal duty. • Complying with regulations that apply to us.
• Being efficient about how we fulfil our legal and contractual duties.
• To exercise our rights set out in agreements or contracts. • Fulfilling contracts.

Groups of Personal Information
We use many different kinds of personal information, and group them together like this.

Type of personal information Description
Contact – Where you live and how to contact you.
Socio-Demographic – This includes details about your work or profession, nationality, education.
Contractual Details about the services we provide to you.
Locational Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet.
Technical Details on the devices and technology you use.
Communications What we learn about you from letters, emails, and conversations between us.
Social Relationships Your family, friends, and other relationships.
Open Data and Public Records Details about you that are in public records such as the Electoral Register, and information about you that is openly available on the internet.
Usage Data Other data about how you use our services.
Documentary Data Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or birth certificate.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Genetic and bio-metric data
• Health data including gender                                                                                                                                      Criminal convictions and offences

Consents

Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you, whether you get paper payslips.
National Identifier A number or code given to you by a government to identify who you are, such as a National Insurance number.

Where we collect personal information from
We may collect personal information about you (or your business) from these sources:
Data you give to us:

• When you apply for our services
• When you talk to us on the phone or in the office
• When you use our websites, mobile device apps, web chat or social media services
• In emails and letters
• In interviews
• In customer surveys
• If you take part in any competitions or promotions.
Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:
• Payment and transaction data.
• Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we work with:

• Companies that introduce you to us
• Credit reference agencies
• Social networks
• Payroll service providers
• Public information sources such as Companies House
• Agents working on our behalf
• Market researchers
• Government and law enforcement agencies.

Who we share your personal information with
We may share your personal information with third parties and these organisations:

• HM Revenue & Customs, regulators and other authorities
• Any party linked with you or your business’s product or service
• Companies we have a joint venture or agreement to co-operate with
• Organisations that introduce you to us
• Companies that we introduce you to
• Market researchers
• Companies you ask us to share your data with.

We may need to share your personal information with other organisations to provide you with the service you have chosen:
• If you use direct debits, we will share your data with the Direct Debit scheme.

How we use your information to make automated decisions
We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.
Here are the types of automated decision we make:
Pricing
We may decide what to charge for some services based on what we know.

Opening accounts
When you open an account with us, we check that the service is relevant for you, based on what we know. We also check that your business meets the conditions needed to open the account. This may include, residency, or financial position.
Approving credit
We use a system to decide whether to open and account for your business. This is called credit scoring. It uses past data to assess how you’re likely to act while paying back any money you owe.

Credit scoring uses data from two sources:
• Credit reference agencies (HSBC)
• Data we may already hold.

It gives an overall assessment based on this. Banks and other lenders use this to help us make responsible lending decisions that are fair and informed.

Credit scoring methods are tested regularly to make sure they are fair and unbiased.

Your rights

As a person you have rights over automated decisions.
• You can ask that we do not make our decision based on the automated score alone.
• You can object to an automated decision, and ask that a person reviews it. If you want to know more about these rights, please contact us.

Credit Reference Agencies (CRAs)
We carry out credit checks when you apply for a service for your business. We may use Credit Reference Agencies to help us with this.
If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.
We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

• Company Name, address
• Credit application
• Details of any shared credit
• Financial situation and history
• Public information, from sources such as the electoral register and Companies House.

We’ll use this data to:
• Assess whether your business is able to afford to make repayments
• Make sure what you’ve told us is true and correct
• Help detect and prevent financial crime
• Manage accounts with us
• Trace and recover debts
• Make sure that we tell you about relevant offers.

We will go on sharing your personal information with CRAs for as long as you are a client. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. If you owe, it will also include details of your repayments and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us.
When we ask CRAs about your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.
CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights.

Sending data outside of the EEA
We will only send your data outside of the European Economic Area (‘EEA’) to:
• Follow your instructions.
• Comply with a legal duty.
• Work with our agents and advisers who we use to help run your accounts and services.
If we do transfer information to outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services. It could mean that we cancel a service you have with us.
Any data collection that is optional would be made clear at the point of collection.

Marketing
We may use your personal information to tell you about relevant offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing services.
We may ask you to confirm or update your choices, if you take out any new services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.

How long we keep your personal information
We will keep your personal information for as long as you are a client/candidate/ supplier of Arena.
After you stop being a client/candidate/ supplier , we may keep your data for up to 1 year for one of these reasons:

• To respond to any questions or complaints.
• To show that we treated you fairly.
• To maintain records according to rules that apply to us.

We may keep your data for up to 7 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
Arena Personnel Ltd
Suite C The Colonnade
Letchworth Garden City
Hertfordshire SG6 3AQ

Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:

• It is not accurate.
• It has been used unlawfully but you don’t want us to delete it.
• It not relevant any more, but you want us to keep it.
• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
• If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.

How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain services to you. If this is so, we will tell you.

How to complain
Please let us know if you are unhappy with how we have used your personal information. You can contact us using our website www.arena-group.co.uk.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Future formats for sharing data
The Data Privacy laws changed on 25 May 2018. From this date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

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