General Privacy Notice
Data controller: Virtual Operations Limited, Palladium House, 1-4 Argyll Street, London W1F 7LD
Virtual Operations Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Virtual Operations Ltd is committed to protecting and respecting the privacy of all of business contacts.
Virtual Operations Ltd (“We”, “The Company”) collects, stores and processes personal data, in the form of contact details, relating to its clients and other business contacts, in order to effectively manage our working relationships and fulfil contractual obligations. This privacy notice sets down how the Company collects and uses personal information about you during and after your working relationship with us.
The Company is committed to protecting the privacy and security of your personal information. The Company is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.
2. Data Protection Principles
The Company will comply with data protection law, including the European Union’s General Data Protection Regulation (GDPR) and the UK Data Protection Act. This means that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with these purposes;
- Relevant to the purposes we have told you about and limited to those purposes only;
- Accurate and kept up to date;
- Kept only for such time as is necessary for the purposes we have told you about; and
- Kept securely.
What Information Does the Company Collect and Process?
Personal data means any information about an individual from which the person can be identified. The Company collects and processes personal information (personal data) about you which will depend on the nature of your relationship with us:
- In order for you to use our Academy services and to manage your account, including sending you information regarding your courses, subscription, certifications or payments, we process your email, and first & last name, employer for performing your contract with us;
- In order to report your performance to employers/sponsors, we process your email, and first & last name, user performance for performing your contact with us;
- In order for you to become a VOLT subscriber, we process your email, first and last name, company and location for performing your contract with us.
Support Service/VOICE Users:
- In order for us to resolve queries submitted to our Support Desk, we process your username, email, first and last name, location, employee number and phone number for performing your contract with us.
- In order for us to resolve queries submitted via our VOICE contact form, we process your username, email, first and last name, phone number and job role for performing your contract with us.
- Please refer to our Website Privacy and Cookie Policies.
Clients and Prospective Clients (Consulting Services):
- In order to effectively fulfil contractual obligations, or to take steps at your request in order to enter into a contract with us, we may process your email, first and last name, company, job title, country, personal or office address and telephone number.
The Company collects information in a variety of ways. For example, data is collected when contact is made through work-related activities, when you subscribe to a product or service, or when you contact the company for further information, or to register an interest in our products and services.
Data is stored in the Company’s email system, and where relevant in other IT systems (where required for documentation necessary to execute work and meet other contractual obligations).
4. Why Does the Company Process Personal Data?
The Company needs to process data in order to fulfil its contractual obligations in providing services and products, or in order to take steps at the request of the data subject prior to entering into a contract with them. It is in the legitimate interests of The Company and our business contacts to process this personal data in order to respond to queries issued by the data subject.
5. Situations in Which We Will Use Your Personal Information
Situations in which we will process your personal information are listed below:
In order to:
- Communicate effectively in the execution of contracted work;
- Respond to any queries or other requests you submit to us.
Specific details of the situations in which we will process your personal data will be dependent on the nature of your relationship with us, as set out in Section 3.
6. If You fail to Provide Personal Information
If you do not provide certain information when requested, or if you don’t agree to your data being processed, the Company may not be able to fulfil the contract we have entered into with you, be able to take the required steps at your request in order to enter into a contract with you, be able to provide you with our products or services, or be able to respond effectively to any enquires you have submitted to us.
7. Change of Purpose
The Company will only use your personal information for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will advise you of this and explain the legal basis which allows us to do so.
You should be aware that we may process your personal information without your knowledge or consent where this is required or permitted by law.
8. Automated Decision-Making and Profiling
Decisions we make in the execution of our contracted work are not based solely on automated decision-making. We may, in order to keep you informed with relevant information concerning our products and services, build individual profiles using personal information you have supplied, together with navigational and information provided by our partners. We may also use these data for statistical purposes. We will always gain your consent for direct marketing activities.
9. For How Long Do You Keep Data?
The Company will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including any legal, accounting or reporting requirements. After this time, we will ensure the data is deleted in accordance with our data protection policies.
10. Who Has Access to Data?
Your information will be shared with the Training Team, with Finance for accounting purposes, and with the Directors of the company.
Your information will be shared with the VOLT Support Team, with Finance for accounting purposes and with the Directors of the company.
Your information will be shared with the Technical Support Team.
Please note that we will only send direct marketing communications based on your express consent.
Third Party Websites:
From time to time our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you visit any of these sites please note that they have their own privacy policies and you should check these before submitting any personal data. We cannot accept any responsibility or liability for these policies.
Clients & Prospective Clients (Consulting Services):
Your information will be shared with the commercial Delivery Team engaged to execute the work for which we have entered into a contract with you/for which we mutually intend to enter into a contact, with Finance for accounting purposes, with the Technical Support team as and when required, and with the Directors of the company.
Disclosure to other parties:
As defined in section 736 of the UK Companies Act 1985 we may disclose your personal information to any member of our group. These include our subsidiaries, our ultimate holding company and its subsidiaries.
The Company shares your data with third parties where required by law, where it is necessary in order to administer the working relationship with you or where we have another legitimate interest in doing so. The Company may also share your data with other third parties:
- To the prospective buyer or seller of any business or assets in the event that we sell or buy. In those circumstances the data will be subject to confidentiality arrangements.
Your data may be transferred to countries outside the European Economic Area (EEA) in order to facilitate business transactions. Data is transferred outside the EEA on the basis of declaration of adequacy, binding corporate rules and other safeguards.
11. How Does the Company Protect Data?
The Company takes the security of your data seriously. The Company has internal policies and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Details of these measures are available on request.
When the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and current. Please be sure to keep us informed if your personal information changes during your period of engagement with us.
12. Your Rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request (known as a “data subject access request”);
- require the Company to change incorrect or incomplete data;
- request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
- ask the Company to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
[If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact Clare Horn (Data Protection Officer) (firstname.lastname@example.org)
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.