Privacy Policy

Swann Group Limited is committed to complying with its legal obligations under the General Data Protection Regulation 2016 (“GDPR”) and to the protection of the rights and freedoms of individuals whose personal data Swann Group Limited obtains or generates as part of its business operations.

This policy describes how and why we collect, store and use personal data and also provides information about individuals’ rights. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

In this policy “we”, “us” and “our” means the Swann Group of companies responsible for any personal information collected about you.

What personal data do we collect and process?

In order for us to operate our business we need to collect personal data from those who access our websites or premises, obtain products or services from us, provide products or services to us, are engaged by us or who we otherwise have dealings with in the course of our day to day activities.

We are committed to ensuring that the personal data we collect and use is appropriate for this purpose and does not constitute an invasion of an individual’s privacy. This section sets out further details of the types of personal data we collect in different circumstances and how it is used by us.

Visitors to www.swanngroupltd.com and our other websites

If you visit our websites your personal data including your name, email address, telephone number and other contact information will be collected if you register to use the website (where registration is required), subscribe to one of our services, post material or request further services. We may also ask you for information if you report a problem with a website.

We may collect details of your visits to our websites including traffic data, location data, weblogs and other communication data as well as details of the resources that you access. We may also collect information about your computer including, where available, your IP address, operating system and browser type. This information is used for system administration and to report aggregate information to our advertisers.

We use information held about you in the following ways:

• To ensure that content from our websites is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our service, when you choose to do so.
• To notify you about changes to our service.
• Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Customers and related individuals

We collect personal data from our customers and related individuals where necessary to provide our services or where an individual has otherwise consented to its collection.

We may use the personal data collected for the purposes of:

• Providing our products and services to you or the organisation you represent.
• Operating back office and administration services connected with the provision of our products and services.

Suppliers and third party service providers (including individual contractors)

We may collect personal data including your name, email addresses, telephone numbers and other business contact information for the purposes of receiving services or quotations, managing relationships, providing services to our clients and operating our business.

We may use and disclose the information we collect in such manner as we believe to be necessary to enable us to carry out our business and to receive the services being provided. This includes the use of personal information in connection with billing, invoicing, payment and legal enforcement.

Swann Group Limited personnel

Personal data in relation to Swann Group Limited personnel is collected and held on our systems and applications. Further information regarding the collection and use of personal data of Swann Group Limited personnel is provided as part of our induction process, and is available to view on the Company Intranet at any time.

Job applicants

If you register interest in applying for a vacancy with Swann Group Limited or submit an application for a vacancy, we will collect your name and contact details including your address, email address and telephone number. More detailed personal data may also be collected where you are the subject of a vetting process which may include details of your employment and education history, references, professional memberships and qualifications, credit check results, criminal records check results, DVLA details and proof of identity documents.

Information we collect will be used by us to process and progress your application and to complete our induction processes should you go on to be employed or engaged by us.

Your rights as a data subject

As a data subject you have certain rights which you may exercise if we are in possession of, or are processing, your personal data. Specifically:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – you have a right, in certain circumstances, to ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your personal data.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.

To exercise these rights please contact us using the contact details set out in the Contact Information section below. In the event that Swann Group Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the Complaints section below.

On what basis do we process personal data?

We will only process personal data where we have a lawful basis on which to do so. The lawful basis on which data is processed will depend on the nature of the information collected and the purposes for which it is used by us but will be one or more of following:

• Consent: you have provided your consent for us to process your personal data for a specific purpose.
• Contract: the processing is necessary for a contract you have with us or because you have asked us to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for us to comply with our legal obligations.
• Vital interests: the processing is necessary to protect someone’s life.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party.

For how long do we hold personal data?

Swann Group Limited will only retain personal information for the period necessary to fulfil the purposes for which it is collected and processed, or for such shorter or longer period as may be prescribed by applicable law or Swann Group Limited’s internal policies and procedures.

Transferring and storing your data

The data that we collect from you will not be transferred to, or stored at, a destination outside the European Economic Area (“EEA”).

Information provided via our websites

All information provided via www.swanngroupltd.com or associated websites, is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Disclosure of your information

We may disclose your personal information to any member of our group, which means Swann Group Limited, it subsidiaries and subsidiary undertakings from time to time (as defined in the Companies Act 2006).

We may also disclose your personal information to third parties in certain circumstances including:

• We may provide personal data to clients, third party suppliers, service providers, professional advisors and other business partners to enable us to provide or receive products or services.
• In connection with the administration and operation of our business we may provide personal data to third parties who provide support services including IT, finance and accounting and HR services and research, marketing, business development and consultancy services.
• In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
• We may disclose or share your personal data if we are under a duty to do so in order to comply with any legal obligation or where necessary to enforce any legal right or contractual agreement, or to protect the rights, property, or safety of Swann Group Limited, our employees, customers, or others. This includes exchanging information with other companies, organisations and bodies for the purposes of fraud protection and credit risk reduction.

Links to other websites

Our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Changes to our Privacy Notice

This Privacy Notice was last updated in May 2018. Any changes we may make to our Privacy Notice in the future will be posted on this page and we suggest that you check back frequently to see any updates or changes.

Contact information

Our Data Protection Officer is responsible for the management of personal data within Swann Group Limited and for ensuring that compliance with data protection legislation and good practice can be demonstrated. Questions, comments and requests regarding this Privacy Notice or our collection or use of personal data should be addressed to:

The Data Protection Officer

Kent House

60b Priory Street

Tonbridge, Kent

TN9 2AH

Complaints

If you wish to make a complaint about how your personal data is being processed by us (or the third parties referred to in this Privacy Notice), or how your complaint has been handled, you have a right to lodge a complaint with our Data Protection Officer using the contact details above or by contacting:

The Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow, Cheshire

SK9 5AF