Privacy Policy

 

1. Introduction

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to personal information processed by or on behalf of Neptune International.
This is the privacy notice of Neptune International, Office 7, Barnwell House, Barnwell Drive, Cambridge, CB5 8UU (Trading address). We are a data controller of your personal data.
We have a dedicated data protection officer (“DPO”). You can contact the DPO using the details below or by writing to us at the address at the bottom of this privacy notice, marking it for the attention of the DPO, or by emailing info@neptuneinternational.org
Updates to our privacy notice
We may change this privacy notice on occasion to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website: https://www.neptuneinternational.org/privacy-policy

2. Types of personal information we hold and process
If you are an applicant, personal information that we hold about you may include the same information listed above, along with your language, gender, date of birth, social network accounts, education, work history, skills, aptitudes, CV, salary/benefit information, information derived from background checks such as criminal convictions and credit records, banking details, driver’s license number, information about your health, (including any medical condition and health and sickness records) and information about your hobbies and interests. We may also process your function/job title and your work email address and your company’s name, postal address, VAT and/or company number. It will also include any personal information we derive about you through the administration of skills, personality or aptitude testing.
We will process personal data in connection with all of our products and services, if relevant, including:
• Personal and contact details, including but not limited to title, full name and contact details
• Records of your contact with us such as via the telephone, through one of our website contact forms, or by email
• Your expressed job requirements, including job title and place of employment.
• Products and services you have received from us, as well as those you have been interested in
• Your date of birth, gender, age (where provided) and marital status.
• Passport information and your nationality, if supplied for the purposes of finding an employment and immigration work.
• Your residency and/or citizenship status, if relevant and required for the processing of your employment and immigration work.
• Family members complete personal details , if supplied for the purposes of processing your employment and your and theirs immigration work.
• Post Employment follow up communications, including reviews, complaints and general feedback.
• Marketing to you, including history of our marketing communications, whether you open digital communications or click on links, and information about products or services we think you may be interested in.
• Insights about you gained from analysis or profiling of our database and the information we hold about you.
• Online behavioural data including IP Address, Browser Type, Browser Version and pages of website visited.

3. Sources of the personal information we hold about you
We typically collect personal information from the following sources:
• Information supplied by you when you looking for an employment opportunity from us, either over the telephone, via email, through one of our website contact forms.
• Information supplied by you when book a immigration service with us.
• If you have cookies enabled on your computer, we may also collect information that your browser sends us whenever you visit our website. This data may include information such as your computer’s IP address, browser type, browser version, the pages of our Website that you visit and other statistics relating to your use of the Website. This information may be collected in conjunction with third party services such as Google Analytics. The information we collect is aggregated to produce statistics that cannot be linked to you. We use this information to provide you with a better experience, to improve our services, and to analyze and understand how our website and products are used.

4. Why we use your personal data
We use your personal data, including any of the personal data listed in section one above, for the following purposes:
• Supplying you with the product or service you have booked with us
• Providing you with information, such as a immigration service, that you have requested from us
• To provide insight and analysis of our clients and staff, to help us improve products and services, and to assess or improve our business operations
• To share information, as needed, with Employers (NHS or Private), UKBA Home Office as part of our contract with you to provide and administer the products and services you have purchased from us
• To comply with legal and regulatory obligations and requirements.
• Updating your records and the information we hold about you.
• For market research and analysis of our clients and business operations
• For the management and auditing of our business operations
• To detect and prevent fraud
• To monitor and to keep records of our communications with you and our staff
• For direct marketing communications, including customer profiling to help us to offer you products and service which we believe to be relevant to your interests, including deciding whether or not to offer you certain products and service. We’ll communicate to you by email, phone, post.
• To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and other communications
• To review and improve current products and services, as well as develop new ones

5. Legal grounds of processing your personal information
We use the following legal bases to use your personal data:
a. Where it is needed to provide you with our products or services, such as:
• All activities relevant to delivering the service including Finding an employment opportunity, Book UKBA Home Office immigration service, post-employment communications etc.
• Managing Service bookings you hold with us
• Sharing your personal information with with Employers (NHS or Private), UKBA Home Office
b. With your consent or explicit consent:
• For direct marketing communications
• For profiling and other automated decision making
• For, where required, processing of special categories of personal data such as that about your health or criminal records information.

c. To comply with our legal obligations

d. Where it is in our legitimate interests to do so, such as:
• For market research and analysis
• For direct marketing communications, including customer profiling to help us to offer you products and service which we believe to be relevant to your interests, including deciding whether or not to offer you certain products and service. We’ll communicate to you by email, phone, post.
• Where we need to share your personal information with partner organisations in order to run our business or comply with legal and/or regulatory obligations that govern our business operations.

6. Proving your personal information to us
In circumstances where providing personal information is non-compulsory to the delivery of our products or services, we’ll make this clear in our communications to you. However we will be unable to provide you with our products or services if you do not provide certain information to us

7. Direct marketing by us and your marketing preferences
We may use your home address, phone number(s), email address to contact you according to the marketing preferences we hold on record for you.
You can request us to stop our marketing at any time by contacting us using the details at the bottom of this privacy notice, or those provided in the specific communication.

8. Opting out of or withdrawing your consent to direct marketing
Where we’re relying upon your consent to process personal data, you can withdraw this at any time. If you no longer want to hear from us, you can opt out or unsubscribe by:

• Clicking on the ‘Unsubscribe’ link in any of the e-newsletters we send (this applies to email communications only)
• Emailing us at info@neptuneinternational.org
• Writing to us at: Neptune International, Office 7, Barnwell House, Barnwell Drive, Cambridge, CB5 8UU
• Or telephoning us at 01223 411265.
You can also use the contact details above to advise us of any changes to your personal information and we’ll update your records accordingly.

9. Sharing of personal information with other organisations
We may share information with the following third parties for the purposes of providing you with the products and services you have requested from us (such as a Immigration Service) as well as when you book with us. These third parties include our with Employers (NHS or Private), UKBA Home Office.

10. Transfer of personal data outside the UK or the EEA
Neptune International is based in the UK but when you request/book a product or service from us that involves a business partner outside of the UK or EEA, we will share your personal information outside the European Economic Area. In these instances we endeavour to ensure suitable safeguards are in place, for example by using contractual agreements to stipulate the safe processing of the data we share.

11. Monitoring of communications involving processing of your personal information
For the purposes of this privacy notice, monitoring means any: listening to and recording of calls, viewing of, intercepting of or saving emails, keeping records of meetings and other communications.
We may monitor communications where permitted by law to comply with regulatory rules and to prevent or detect crime, as well as to enforce procedures for quality control and staff training purposes.

12. Keeping your data secure
Neptune is committed to:
• seeking to safeguard all personal information that you provide to us;
• seeking to ensure that it remains confidential and secure; and
• taking all reasonable steps to ensure that personal privacy is respected.
We will use technical and organisational measures to safeguard your personal data, for example:
• We store your personal data on secure servers; and all the information in hard copy is securely locked.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us by emailing at : info@neptuneinternational.org.

13. Data retention (GDPR)
We will hold your personal information based on the following criteria:
• For as long as required for us to provide goods and/or services to you and subsequently for as long as you are legally entitled to bring a claim against us; and/or
• Retention periods in line with legal and regulatory requirements or guidance; and/or
• For as long as we have reasonable business needs

We only keep your personal data as long as necessary for the purpose for which it was obtained. After that period, we either: (1) anonymise the data if we still wish to use it for analytical purposes, or (2) pseudonymise the data if believe in good faith that we may need to process the data in the future for a legitimate purpose, or in all other cases (3) delete it completely from our servers.

14. Rights under data protection laws (GDPR)
The Data Protection Act gives rights to individuals in respect of the personal data that organisations hold about them. Below is a list of these rights. It is important to note that they don’t all apply in all circumstances.
• a right of access to a copy of the information comprised in your personal data;
• a right to object to processing that is likely to cause or is causing damage or distress;
• a right to prevent processing for direct marketing;
• a right to object to decisions being taken by automated means;
• a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk

Contact Us
If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by:
• Emailing us at info@neptuneinternational.org
• Writing to us at: Neptune International, Office 7, Barnwell House, Barnwell Drive, Cambridge, CB5 8UU • Or telephoning us at 01223 411265

Neptune International |Privacy Notice | 19.10.2018