## INTRODUCTION
Welcome to the Privacy Notice of Diligence Hub, a service provided by The Freelancer and Contractor Services Association Ltd ('FCSA').
FCSA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit this website, and when we contact you directly as part of our work (including Diligence Hub outreach), and tell you about your privacy rights and how the law protects you.
This privacy notice deals with the specific areas set out below. Please use the glossary below to understand the meaning of some of the terms used in this privacy notice:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
## 1. IMPORTANT INFORMATION AND WHO WE ARE
### PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your personal data, whether through your use of diligencehub.co.uk or because we have contacted you directly using details obtained from other sources.
This website is not intended for children under 16 and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
### CONTROLLER
Diligence Hub is operated by FCSA, which is the controller and responsible for your personal data (collectively referred to as "Diligence Hub", "FCSA", "we", "us", or "our" in this privacy notice).
We have appointed a Data Protection Representative (DPR) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPR using the details set out below.
### CONTACT DETAILS
Our full details are:
– Full name of legal entity: The Freelancer and Contractor Services Association Ltd
– Name and title of DPR: Chris Bryce, Chief Executive
– Email address: info@fcsa.org.uk
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
### CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on [date]. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
### THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave this website, we encourage you to read the privacy notice of every website you visit.
## 2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the ability to identify the person has been removed.
We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
– **Contact Data** includes your name, email address, company name and details of your enquiry, if you have contacted us through this website.
– **Diligence Hub Outreach Data**, where we have contacted you directly rather than the other way round, includes your name, job title, employer, work email address and work telephone number.
– **Technical Data** includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
– **Usage Data** includes information about how you use this website.
– We also collect, use and share **Aggregated Data** such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
– We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
### IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have arranged with us but we will notify you if this is the case at the time.
## 3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you, including through:
– **Automated technologies or interactions.** As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
– **Third-party business databases.** For Diligence Hub outreach, we obtain contact details (name, job title, employer, work email and work telephone number) from third-party business information services, including Apollo.io, and from publicly available professional profiles such as LinkedIn. We contact people whose role covers workforce supply and procurement, because FCSA accredits employment intermediaries against a compliance code that organisations such as NHS framework suppliers are often asked to meet. We have not collected this information from you directly.
– **Analytics providers.** We may receive Technical Data from analytics providers such as Google, based outside the EEA.
– **Contact Form.** When you use a contact form on this site the information you provide is stored in a log. When you subscribe to our e-newsletter we will store the data you provide.
## 4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your data (a) where it is necessary for our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests, (b) where we need to comply with a legal or regulatory obligation, or (c) where it is necessary for the purpose of entering into a contract with you.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. Where you have given your consent to receiving marketing communications, for example by subscribing to our e-newsletter, you have the right to withdraw consent to receiving them at any time by unsubscribing or contacting us.
### PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We may use your Technical Data to administer and protect this website. Such use would be necessary for our legitimate interests, and to comply with a legal obligation.
We may use your Usage Data and Technical Data to deliver relevant website content to you and measure or understand the effectiveness of the content. Such use would be necessary for our legitimate interests.
We may use your Usage Data and Technical Data to improve this website, our services, marketing, customer relationships and experiences. Such use would be necessary for our legitimate interests.
We use the information you have provided in our contact form to communicate with you in relation to our services. Such use is necessary for our legitimate interests or necessary for the purpose of entering into a contract with you.
**We use Diligence Hub Outreach Data to make people whose role covers workforce supply and procurement aware of FCSA's accreditation standards.** Such use is necessary for our legitimate interests, namely raising awareness of compliance standards among professionals for whom this subject matter falls squarely within their own job role. We have assessed that this interest does not override your rights and freedoms, taking into account that the data used is limited to professional, work-related contact details, and that FCSA is a not-for-profit standards body rather than a commercial sales operation. You can object to this processing at any time; see Your Legal Rights below.
Where you have given consent, we use the information you have provided in our contact form to send you direct marketing materials. You will have the opportunity to unsubscribe each time we send a newsletter to you.
### MARKETING
We do not share your personal data with any third-party company for their own marketing purposes. We may send your data to third-party processors who assist us with our marketing, as set out in Disclosures of Your Personal Data below.
### COOKIES
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. For more information about the cookies we use, please see our separate cookie policy.
### CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
## 5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below, for the purposes set out in section 4 above:
**Apollo.io**, which acts as a processor and is the source platform from which we obtain Diligence Hub Outreach Data.
**HubSpot**, which acts as a processor and is the customer relationship management system in which your data is held if you engage with us.
Other external third parties as set out in the glossary, including PR, market research, marketing, communication, IT and system administration providers, and professional advisers such as lawyers, bankers, auditors and insurers.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
## 6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the United Kingdom, so their processing of your personal data may involve a transfer of data outside the UK. Whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it, for example through adequacy regulations or standard contractual clauses. Please contact us if you want further information on the specific mechanism used when transferring your personal data.
## 7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
## 8. DATA RETENTION
### HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law, we have to keep basic information about our customers for six years after they cease being customers, for tax purposes.
**Diligence Hub Outreach Data** is retained only for as long as we are actively seeking to make contact. If there has been no engagement from you within 12 months of first contact, we will delete your details.
## 9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection law in relation to your personal data. Your rights are listed below, and more detail can be found in the glossary below:
– Request access to your personal data.
– Request correction of your personal data.
– Request erasure of your personal data.
– Object to the processing of your personal data.
– Request restriction of processing your personal data.
– Request transfer of your personal data.
– Right to withdraw consent.
If you have received a Diligence Hub outreach email and wish to object, you can simply reply to that email with the word "remove", and we will delete your details and will not contact you again.
To exercise any of the rights set out above, please email dataprotection@fcsa.org.uk.
### NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data, or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.
### WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask for further information in relation to your request, to speed up our response.
### TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer, in which case we will notify you and keep you updated.
## 10. GLOSSARY
### LAWFUL BASIS
**Legitimate Interest** means the interest of our business in conducting and managing our activities, including raising awareness of FCSA's accreditation standards among relevant professionals. We make sure we consider and balance any potential impact on you, both positive and negative, and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted by law. You can obtain further information about how we assess our legitimate interests against any particular impact on you by contacting us.
**Comply with a legal or regulatory obligation** means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
### EXTERNAL THIRD PARTIES
– Apollo.io, a third-party business information service, acting as a processor for Diligence Hub outreach.
– HubSpot, our customer relationship management system, acting as a processor.
– Service providers acting as processors based in the UK, EEA and USA who provide PR, market research, marketing, communication, IT, system administration and other services.
– Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
– Tax, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
### YOUR LEGAL RIGHTS
**Request access to your personal data** (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
**Request correction of the data that we hold about you.** This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
**Request erasure of your personal data.** This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law.
**Object to the processing of your personal data** where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground, or where we are processing your personal data for direct marketing purposes, including Diligence Hub outreach.
**Request restriction of processing of your personal data.** This enables you to ask us to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the data's accuracy, or where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
**Request the transfer of your personal data** to you or to a third party, in a structured, commonly used, machine-readable format. This right applies only to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
**Withdraw consent** at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
