GDPR and E Privacy Policy

Velvet Apple Media Ltd GDPR & E Privacy Policy

TERMS AND CONDITIONS OF THE CONTRACT: YOUR RIGHTS UNDER GDPR & EPRIVACY

This contract is between you, the data subject, and Velvet Apple Media Ltd

The contract is at the request of the data subject.

Your privacy is important to us and we take it very seriously. We want to help everyone who uses our services to get the most out of them. The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25^th May 2018. Furthermore the Information Commissioner’s Office (ICO) has recently laid out its intention to continue with a similar level of regulation post March 2019.

The policy below lays out in simple English how the GDPR applies to the way Velvet Apple Media Ltd handles your personal data. Our aim is to be responsible, relevant and secure when using your data. Velvet Apple Media Ltd specialises in Recruitment business and industry news, commercial product information and events.  Our aim is to keep you informed and up to date about these areas using digital newsletters, supplier and event updates together with our online magazine. We would like to continue this service after 25^th May  2018 so have put in the place the following privacy policy.

Please take a moment to read through what information we collect about you, who we share it with and how they might use it.

WHO CONTROLS MY PERSONAL DATA?

1. The Data Controller is Velvet Apple Media ltd. It is registered in the UK Company Number 8030836
2. The registered address is 424 Margate Road, Westwood, Ramsgate, Kent CT12 6JS
3. The Data Controller’s representative is the Director of Data Protection.
4. You can contact them by email at datacontroller@velvet-apple.com
5. You can call them on 0207 1830117
6. Velvet Apple media Limited is registered as a Data Controller with the Information Commissioner’s Office Certificate Number ZA355807 
7. Velvet Apple Media Ltd refers to both the parent company, and its’ subsidiary brand, Recruitment Agency Now.

WHAT DATA WILL THE CONTROLLER COLLECT AND PROCESS?

1. The categories of personal data collected are your name, your job title, your company name, your company address and your business email.
2. Personal Data may also include a link to a professional profile including a photograph if one is available in the public domain e.g. LinkedIn, Twitter, Business Facebook or Corporate Website.
3. No links to personal or private websites – even if they are in the public domain will be collected, stored or processed.
4.  

WHAT IS THE PURPOSE AND LEGAL BASIS OF THE PROCESSING?

1. Velvet Apple Media Ltd will rely on Article 6(1)(f) GDPR as a lawful basis for processing your personal data.
   1. Article 6 (1)(f): ‘processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental right and freedoms of the data subject which require protection of Personal data, in particular where the data subject is a child’.
2. Specifically, Recital 47 affirms direct marketing as a legal basis for processing by the Controller or Third Party provided that the interests or the fundamental rights and freedoms of the data subject are not overridden.
   1. Recital 47: The legitimate interests of a controller, including those of a controller to which the Personal data may be disclosed, or of a third party, may provide a legal basis for processing, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of the data subject based on their relationship with the controller’.
   2. ‘The processing of personal data for direct marketing purposes maybe regarded as carried out for a legitimate interest’.
3. Velvet Apple Media Ltd undertake to balance the rights of the individual data subject, taking into consideration the reasonable expectations of data subjects and the provision of Recital 47.
4. By continuing to receive newsletters and/or visit our websites you are agreeing that you understand and accept this as a valid legal basis for processing your personal data.
5. You will always be given a straightforward way to opt out from receiving newsletters or updates we send you each time you receive a communication from us.
6. The activities of Velvet Apple Media Ltd will be limited to First Party Emailing which may include third party content.

WHO WILL HAVE ACCESS TO MY DATA?

1. Velvet Apple Media Ltd. All our employees and data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
2. It may be necessary for the purposes of delivering digital communication to share personal data with technology platforms e.g. mail servers. We guarantee to only to use suppliers who meet the GDPR standards.
3. We may share your details with relevant clients of VA Media Ltd, these include, supplier firms who serve those areas, including Recruitment Agency Consultancies and Business Services.

WILL THE DATA LEAVE THE UK? IF SO, WHAT SAFEGUARDING MEASURES ARE IN PLACE?

1. Velvet Apple Media Ltd has advises all parties that at this current time no personal data will be transferred outside of the UK

HOW LONG WILL PERSONAL DATA BE RETAINED FOR? ARTICLE 13(1)(A)

1. The Retention period for data is three years from the signup date or sooner if you choose it. We have chosen three years because that is the average amount of time a professional in the UK remains in post.
2. All Data Controllers will be required to deactivate personal data after the relevant retention period, or when they are in receipt of a data subjects request to do so, whichever is the earlier. The data subject has the right to change their mind and withdraw consent at any point during the retention period. Article 21(4) – ‘Right to Object’.

WHAT ARE MY RIGHTS? ARTICLE 13(1)(C)

Velvet Apple Media Ltd confirms the following rights to each Data Subject:

1. Personal data shall be processed in accordance with Principle 6 of the rights of data subjects under the Data Protection Act.
2. The right of access to a copy of the information comprised in their personal data. To obtain a copy of the personal information we keep about you please send your request to the Data Controller Velvet Apple Media Ltd  Suite 3.4, 23 Banks Studios, Park Royal, London, NW10 7LQ. We will provide you with a hard copy of the personal data we keep (at no charge) within 40 days. We will, however, require proof of identity.
3. The right to object to processing that is likely to cause, or is causing damage or distress.
4. The right to prevent processing for Direct Marketing.
5. The right to object to decisions being taken by automatic means.
6. The right to have inaccurate personal data rectified, blocked, erased or destroyed.
7. The right to make a complaint to a supervisory body.