1. About us
The terms of this Policy may change from time to time. If we make changes we will notify you by updating the Policy on our websites.
In the context of this Policy the Solace group is the ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this Policy as “we”, “us” or “our”. The term Data Controller means that the Solace group determines the purposes and way in which any personal data you provide to us is, or will be, processed.
Should you need to contact us regarding this Policy or the matters it refers to please email email@example.com quoting ‘Security & Privacy Enquiry’ as the subject, or write to Data Protection Officer, Solace Group, Off Southgate, Pontefract WF8 1NT.
2. Personal information we may collect
Personal information may be collected through use of the company websites or through other points of contact relevant to the Solace group activities you wish to engage with. For example, we collect personal information when you:
- deal with us in person or by telephone, email or letter;
- fill out and submit a membership application form;
- make an enquiry or complete a web form;
- register to attend an event;
- register for learning and development activity;
- sign-up for policy briefings and/or other updates from the Solace group;
- apply to register with the Solace group as an interim candidate or for permanent recruitment opportunities;
- respond to a client recruitment opportunity advertised by the Solace group; or
- submit any other information in connection with your application for membership or the purchase of other products and services.
The types of personal information collected will be relevant to the product or service. We may also request personal information to enable Solace to analyse and report on diversity in public sector leadership and/or recruitment and to gain a broader understanding across the sector. Information collected/requested may include your title, first name, surname, gender, ethnicity, date of birth, qualifications and home and work contact details (telephone, street address, email address). If relevant to the product or service being provided we may also collect information relating to your current/past employment, including job title(s), areas of expertise and your job function(s). In applications for some categories of membership and for interim and permanent recruitment opportunities we ask you to identify referees and to provide contact information for them.
We may also collect information for marketing purposes and analysis, including information on how responses vary for email, SMS/text, phone and other forms of communication.
When purchasing a product or service for which payment is being made through debit or credit card or via direct debit arrangements, details relating to your debit or credit card or bank account are collected and are temporarily stored until we have processed your order and the selected payment method is completed.
3. How we use your information
Data protection legislation says that we are allowed to use and share your personal data only where we have a proper reason to do so. The law says we must have one or more of the following reasons:
- Contract – your personal information is processed in order to fulfil a contractual arrangement e.g. in order to administer your membership of the Solace group or to register you as an interim or permanent recruitment candidate.
- Consent – where you agree to us using your information in this way e.g. for marketing preferences and to receive newsletters.
- Legitimate Interests – this means the interests of the Solace group in managing our business to allow us to provide you with the best products and service in the most appropriate and secure way e.g. to transfer your data to certain Third Parties such as sub-contractors or delivery partners.
- Legal Obligation – where there is statutory or other legal requirement to share the information e.g. when we have to share your information with a regulatory body or for law enforcement purposes.
Using those reasons as appropriate to each circumstance, personal information may be collected and handled by the Solace group for the following purposes:
- to provide you with the services you expect us to;
- to best tailor resources and website content according to your preferences and your internet enabled device;
- to respond to requests or questions when you contact us;
- with your consent we may also use your contact data to inform you about services, products, events, etc that might be of interest to you, via email, telephone, SMS/text or mail;
- to send to you newsletters that may be of interest;
- to help us create, publish and improve content to enhance its relevance;
- to allow you to participate in interactive features of our websites when you choose to do so;
- to perform analytical research on our prospective client and candidate base, including the content and services/products they are interested in;
- to perform analytical research and related reporting on historic membership trends;
- to transfer data to third parties where relevant (see section 7 below);
- to comply with any legal obligation where necessary; and
- we may also process your information to:
a. investigate or respond to incidents and complaints
b. comply with obligations and rights and cooperate with investigations carried out by the police, government or regulators.
Personal information may be used to send direct marketing via email and other communication means when you opt-in for this purpose in the relevant contact form. You may opt-out of receiving future marketing communications at any time by emailing firstname.lastname@example.org
4. Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us when generally navigating our website; however, we cannot fulfil any specific requests for information or provide you with specific products or services unless you do so.
In order to provide you with certain services we may need to collect personal data which data protection legislation regards as sensitive or special categories of personal data, e.g. information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or sexual orientation and/or information relating to any criminal convictions you have or offences you may have committed. By completing our equal opportunities form and/or by providing us with any criminal records information requested for the purposes of providing relevant services to you, you will signify your explicit consent to such sensitive data being processed by us.
Any equal opportunities and diversity monitoring information you provide helps us monitor the effectiveness of our public sector recruitment services and diversity in public sector leadership by gaining a picture of applicants and appointees. Any such information provided will be held in the strictest confidence and used only for the purpose stated. Please note that answers to all equal opportunities questions are optional and a "prefer not to say" response may be provided. However, we may be required to obtain criminal records information from you in order to assess your suitability for certain job roles and if you do not wish to provide your criminal records information then we may be unable to process your application any further.
5. Do we process information using automated systems/processes without human intervention?
The Solace group does not use automated systems/processes and automated decision-making (e.g. profiling) for the provision of its services to you.
6. How long we keep your information for
If we collect your personal information the length of time we retain it is determined by a number of factors, including the purpose for which we use that information and our obligations under relevant legislation.
We may need your personal information for legal, accounting or regulatory purposes. For this purpose we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under ‘How we use your information’ (section 3 above).
The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period or to delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
7. Sharing your information with third parties
To facilitate our efficient use of your information, and to provide you with content and/or services, or to fulfil a request you make of us, we may disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
- To suppliers, contractors and agents: from time to time we may engage or employ other companies and individuals to perform functions on our behalf. Examples include the provision of services in the capacity of a sub-contractor or delivery associate. Such third party recipients will be subject to contractual confidentiality obligations issued to them by the Solace group.
- To technology suppliers: for example, relating to the hosting and/or maintaining of website content or the provision of certain features contained on the Solace group websites. In such circumstances your personal information remains under the control of the Solace group and we ensure that adequate controls are in place (including contractual obligations on the technology supplier) to ensure your personal information is secure.
- To clients: where the purpose of your engagement with the Solace group relates to interim or permanent recruitment activities we may share your personal data with our clients in order to fulfil the relevant service for which you have engaged with us.
- To our Solace Business Partners: information on the Solace Business Partner programme can be found at http://www.solace.org.uk/about/meet_the_partners/ and they may wish to contact you directly about relevant Solace group activity they are involved in.
- To other entities belonging to the Solace group (i.e. any companies directly or indirectly controlled by The Society of Local Authority Chief Executives and Senior Managers (Solace Group) Ltd): data is shared between group companies so we can better serve you or, simply, to fulfil your requests (e.g. when you identify specific services of interested or use ‘contact us’ forms).
- To government or law enforcement authorities: if we determine, in our sole discretion, that the Solace group is under a legal obligation to do so.
Third party recipients will only have access to your personal information as required by them to perform their relevant functions and they are not permitted to use such personal information for any other purposes or for general marketing to you.
8. Transfers to third countries
Information you provide to us will not as a matter of course be transferred outside the European Economic Area (i.e. transfer to a “third country”). Where transfers of data to third countries are identified as necessary for the limited purpose of providing you with the services you expect us to, we shall only transfer your data to countries which the European Commission believes offers an adequate level of protection to personal data..
9. Cookie notice
We collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and we will not use it in isolation to identify you or any individual.
The Solace group websites are based on a content management system and, for the website to function, certain other cookies are stored temporarily on your computer. In particular, the text size widgets utilize cookies to remember the setting between pages and certain other cookies are required to ensure correct functioning of the website and are not used for any other purpose.
You have the ability to accept or decline cookies by modifying the settings in your web browser; however, you may not be able to use all the interactive features of the Solace group websites if cookies are disabled. For information on how to disable cookies, please consult the "Help" tab of your browser via the menu bar.
The information stored in cookies is safe and anonymous to any external third party, and your account security is never compromised. You can find more information about cookies at http://www.allaboutcookies.org/ and www.youronlinechoices.com/
10. Data Security
We will use operational procedures and technical and organisational security measures to mitigate any unauthorised access, change, deletion or transmission of your personal information. Although we do our best in this way to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Solace group websites or any third party; for this reason, any transmission is at your own risk.
11. Links to other websites
12. Your rights regarding access, correction and deletion of personal information
Under applicable data protection laws you are entitled to request the following:
- Right of access; to request access to your personal information and information about how it is processed
- Right to rectification; to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- Right to erasure (also known as the Right to be Forgotten), however this is subject to any legal rights or obligations we may have to retain data
- Right to restriction of processing of your personal information
- Right to data portability; to electronically move, copy or transfer your personal information where appropriate
- Right to object to processing of your personal information
- Rights with regards to automated individual decision making, including profiling
These are called your Data Subject Rights and there is more information about them on the Information Commissioner’s Office website www.ico.org.uk. To exercise your rights, you can email us at email@example.com
To the extent that processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country where you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are available on the website www.ico.org.uk. However, if you believe that your personal information has been or is being used by the Solace group in a way that does not comply with data protection regulations, we encourage you to contact us before making any complaint and we will endeavour to directly resolve any issues or concerns you may have.
13. Keeping in touch with you
We want to keep you up to date with sector briefings, newsletters, opportunities and information relevant to your relationship with the Solace group. We will only send communications to you via email or other means where specified as your contact preference.
On the forms we use to collect your personal information we will usually offer you a check/click box where you can indicate your contact preferences for the type of marketing communications you want to receive.
Where we send marketing communications to you via email you may opt out of receiving individual marketing communications by clicking the ‘unsubscribe’ or ‘optout’ function in the email. In addition, you can also exercise your opt-out right at any time by emailing firstname.lastname@example.org quoting ‘Opt-out’ as the subject and providing the following information: your name, your email address, a contact telephone number, the communications you would like to opt out of receiving. It may take up to 28 days from receipt of your request for this to take place and you may receive further communications in the intervening period while your request is being actioned.
Should you need to contact us please write to: Data Protection Officer, Solace Group, Off Southgate, Pontefract, West Yorkshire, WF8 1NT or via email@example.com quoting ‘Security and Privacy Enquiry’ as the subject.