Privacy Policy: Protecting Your Data at HARBOUR ATS

Introduction

3D MarComms Ltd. is a leading provider of Applicant Tracking Software (ATS) with registered office at Swift House, 18 Hoffman’s Way, Chelmsford CM1 1GU (company number 06603499).

This privacy policy applies to our website visitors and service users. We understand how important your privacy is to you. This privacy policy tells you about the type of information 3D MarComms collect and process, what we do with it, what we do to keep your information secure, your rights and how to contact us. We will only collect the personal data we need to deliver our services, and we hold and process it securely.

Regulation (EU) 2016/679 of the European Parliament (the General Data Protection Regulation (‘GDPR’)) and the Data Protection Act 2018 (referred to as Data Protection Law) oblige us to provide you with information about how and why we use personal data. We recognise our obligations and your legal rights set out in the Data Protection Law.

3D MarComms Ltd. acts as both a controller and processor. We are committed to protecting and respecting your privacy and complying with the principles of the GDPR. We are registered with the Information Commissioner’s Office (www.ico.org.uk) under Payment Tier 2, Z1431519.

This Privacy Policy should be read in conjunction with our Site Terms and Conditions and our Cookie Policy.

Information that we collect from you

The purposes for which we ask for, process and store your personal information includes, but is not restricted to:

Directly providing any services you have requested including responses to questions or complaints;
Responding to an on-line job application;
Enabling third parties to process and manage your information so we can provide the services you have requested;
Contacting you with direct marketing material, where you have consented, should we have news to share with you about our products and services;
Provide a personalised service to you when you visit our websites e.g. by customising the content and/or layout of our pages for each individual user;
In aggregate (and therefore anonymously) to profile your use of the website and carry out research on our users' demographics, interests and behaviour to help us gain a better understanding of how our users navigate and use the websites, and to enable us to improve our service to you;
To purchase services from us;
To communicate with you via third-party social media sites or by email;
Telephoning us, contacting us via our website or by posting something to us and;
Security, administrative and legal purposes.

The type of personal data we may process includes, but is not restricted to:

Contact details (e.g: name, address, phone number)
Site visit details (e.g. your IP address, ISP name, browser type, pages visited, etc.)
Personal details provided or uploaded as an applicant using HARBOUR ATS software, including uploaded CVs and other supporting information requested as part of the recruitment process.

Lawful Basis for Processing

The lawful basis for the data processing involved in the above activities is as follows:

Performance of a contract - steps taken to enter into or in order to fulfil the contract for services that we have with our clients, failure to provide the information necessary to enter a contract with us means that you will be unable to work with us;
Legitimate Interests - which are: to promote 3DMarComms and our activities; to enable us to administrate and run the company efficiently and effectively as a commercial business; and to ensure that we remain accountable to our clients and other relevant stakeholders. We will balance our own interests against your own or the relevant individual whose data is being processed, to ensure that the rights and interests of those individuals who interact with us are protected.
Consent - you have provided your freely given consent to allow us to process your personal data, for example if you have opted-in to receive direct marketing. You have the right to withdraw consent at any time.

All our email correspondence has an unsubscribe option so you can opt out of further email contact if you wish. You can also change your details, including your marketing and communications preferences, by contacting us here.

Data Retention

We will hold your personal data for the length that it is required to provide you with our services in accordance with our Data Retention Policy. We may be required to retain some of your data after this time, for a set period, for us to meet our legal obligations.

Data Sharing

We may sub-contract to organisations to process personal data under a written contract which defines that they must comply with the stringent requirements of Data Protection Law.

Your Rights

You have certain rights set out in the Data Protection Law including:

Your Rights	Description of Rights	Rights in Practice
Right of access	You have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.	We will provide a copy of all personal data belonging to you, or specific personal data if you so require it. This will not include the personal data of any other individuals, or information regarding our operations. We will redact where necessary for the purposes of confidentiality
Right to rectification	You have the right to oblige us to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.	This will only apply to inaccurate personal data; information contained on your application form or any “flags” placed on your record. This will not lead to any other information which you disagree with being rectified, merely personal data which is inaccurate.
Right to erasure (right to be forgotten)	You have the right (under certain circumstances, but not all) to oblige us to erase personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.	The right only applies: Where the personal data is no longer necessary; If you withdraw consent; If we unlawfully held your personal data; If you successfully object to our processing; If we have to follow a legal obligation to delete the personal data.
Right to restriction of processing	You have the right (under certain circumstances, but not all) to oblige us to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.	The right only applies: Where you contend the accuracy of any personal data until it has been made accurate; Where you have objected to any processing whilst we present our evidence; If we are processing anything unlawfully and you do not wish for it to be erased; If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
Right to data portability	You have the right (under certain circumstances, but not all) to oblige us to provide you with the personal data about you which you have provided to in a structured, commonly used and machine-readable format. You also have the right to oblige us to transfer your personal data to another data controller.	This right only applies to data collected by automated means (i.e. excluding paper files) and where the lawful basis for us processing this data is consent or for the performance of a contract. If you wish to obtain your data for the purposes of data portability, then please contact us.
Right to withdraw consent	If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.	We use consent as the lawful basis for sending direct marketing material.
Right to object	You have the right to object (under certain circumstances) to the processing of your personal data. For example, you can object to direct marketing at any time, which includes profiling to the extent that it is related to such direct marketing.	We send out promotional materials via email to market our new products. We offer an unsubscribe function for recipients to opt-out from receiving marketing communications.
Rights in relation to automated decision making and profiling	We do not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.	We do not carry out any automated decision making based on profiling. Where profiling is carried out without automated decision making, we will inform you.

You also have a right to lodge a complaint with the Supervisory Authority should you feel that we have not handled your information in line with legislative and regulatory requirements. This is the Information Commissioner's Office (ICO) in the UK:

Information Commissioner's Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

(e) casework@ico.org.uk

(t) 0303 123 1113

How to Contact Us

For further information regarding approach to handling your personal data please contact our single point of contact for data protection:

Tony McNulty

(e) harbour@3dmarcomms.com

(t) 01621 851151

71 London Road
Copford
Essex
CO6 1LG

Changes to this Privacy Policy

We may change this Privacy Policy from time to time and the amended notice will be posted to the website.

Version Control: Version 2.0 updated 10th July 2019