PEPCO Services LLP takes privacy and its use of your data seriously and acknowledges the importance of protecting any personal information that it holds - such as names, contact details and ID information - hereafter called "Personal Information"
We will ensure that your Personal Information is handled in accordance with the law. The relevant law here is: (i) the UK Data Protection Act 2018, (ii) the EU General Data Protection Regulation (which has replaced the UK Data Protection Act 1998), (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 and (iv) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to PEPCO from time to time (together the "Data Protection Legislation"
PEPCO's services consist primarily of procurement consulting, which provides advice and support surrounding procurement activities. We may have direct contact with you or have been introduced to you via our third party relationships.
When contacting us online, via telephone, in writing or otherwise you may provide Personal Information about yourself to us including your name and contact details (e.g. your address, email address and telephone number). 1.2.2 Information about job applicants
If you apply for or enquire about a job with us we may also ask you to provide details of your previous job title, your employment history, a copy of your CV - and we may also seek references and carry out checks with third parties if appropriate for the role you have applied for. 1.2.3 Information about those related or otherwise connected to our staff
We sometimes ask members of our staff to provide details of their next of kin for the purpose of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements. We will only ever use this information for the benefit of our staff and for the purpose it was provided. 1.2.6 Information about individuals who are our suppliers or other business contacts (and individuals who are employed by our suppliers and business contacts)
If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire your name and contact details.
Some of the Personal Information that we collect (as set out above) is collected and processed for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, correspond with you for business purposes, provide our procurement services, analyse the use of our website and services, carry out effective recruitment and support our staff and clients). 2. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation and our own internal rules and policies allow. 3. YOUR RIGHTS AND DATA ACCURACY 3.1
You have certain rights in relation to your Personal Information - for example the right to request that we erase your Personal Information (or part thereof) at any time, which request we will comply with unless we have a lawful reason to keep your information (for example, to comply with our legal obligations). Please contact us at the email address set out below if you wish to request any changes. 3.2
You also have the right, subject to certain exemptions, to: (a) see the Personal Information we hold about you and withdraw any consent you may have given to us; (b) to ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; and (c) in some cases transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at the email address set out below. 3.3
Please ensure that the Personal Information you provide via the website is accurate and complete and you notify us of any changes to your Personal Information as soon as possible so that we can update our records. 3.4
Whilst we will take all reasonable steps to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose online. You accept the inherent security implications of disclosing Personal Information online. 4. HOW AND WHY WE SHARE YOUR PERSONAL INFORMATION 4.1
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties who reasonably need it in order to perform a function for you or provide a service to us. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We will never sell your data. 4.2
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering obligations), carry out an internal investigation, enforce any agreement we have with you or with a related party, or protect the rights, property, or safety of PEPCO, its group companies and/or our clients, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention. 4.3
In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area ("EEA") to our staff and our third party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to our non-European offices and to third parties based outside the EEA in accordance with the Data Protection Legislation. We may enter into contracts with entities based outside the EEA, where this is required by the Data Protection Legislation – and a copy of the relevant provisions in such contracts will be available to you on written request to the email address below (subject to an undertaking from you to respect the confidentiality of that contract). For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK. 5. MARKETING AND INDUSTRY UPDATES 5.1
Where you have expressly consented to receive from us or we otherwise have the right to send to you marketing materials, event invitations and/or industry updates we will use your Personal Information to do this (whether in hard copy or by email). 5.2
You can opt out of receiving these sorts of communications from us at any time by: (i) contacting us at the email address below, (ii) clicking the unsubscribe/"opt-out" button which are available in some of our emails or (iii) where the materials are sent by post, sending us a cancellation request to the address included in the materials. 6. COOKIES 6.1
We use small files which are stored on your hard drive by our browser ("cookies") to monitor your use of this website during the time you access it. These cookies help us provide you with a better informed website by enabling us to monitor which pages you find useful and which you do not. They do not give us access to your computer or any information about you, other than the data you choose to share with us. Nor are these cookies used to create behavioural profiles of users or for advertising purposes. We do not use the information these cookies collect at any point after you have stopped accessing the website.
In particular, we use the following cookies:
(a) Strictly necessary cookies
. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas.
(b) Performance cookies
. These cookies collect information about how visitors use our website, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies don't collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our website works.
(c) Functionality cookies
. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the website that you can customise. The information these cookies collect is anonymised and they cannot track your browsing activities on other websites.
In particular we use a number of Google Analytics cookies, which are used for the tracking of page views and sessions.
If you do not wish to accept cookies you can disable them by adjusting the settings on your browser. We may also use banners and pop-ups from time to time to give you options around cookies use. Note, however, that certain cookies are necessary to enable the website to operate and refusing or disabling some or all cookies may limit your ability to make use of the website. 7. AGGREGATED DATA 7.1
From time to time we may aggregate statistics, responses to any surveys and questionnaires, traffic patterns and related website information and disclose such aggregated data to third parties (such as PEPCO's suppliers) for the purpose of PEPCO's own marketing, advertising or other promotional purposes. Please note that any such aggregated data will not include any Personal Information and we will never make it available to third parties to use for their own marketing purposes. 7.2
To enable us to monitor and improve this website, we may gather and record on our servers certain aggregated data about you when you use it, including without limitation, the URL that you came from and go to and the parts of our website that you visit. Such aggregated data is primarily used to provide you with an enhanced on-line experience and will not include any Personal Information.
PEPCO may amend this Policy at any time. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the website. Any changes to this Policy will be posted on the website. 9. CONTACT US AND COMPLAINTS 9.1
You can opt out of receiving communications from us at any time by sending an e-mail to firstname.lastname@example.org
or by contacting our Legal Team at the following address: 95 Wigmore Street, London W1U 1FB. 9.2
If you have any questions or concerns about the way in which we have handled your Personal Information, please contact us at the email address above. Alternatively you have the right to make a complaint to the Information Commissioner's Office, the supervisory body in the UK.