Athena Security Solutions

Athena Security Solutions Ltd

PRIVACY POLICY

This privacy policy sets out how Athena Security Solutions Ltd uses and protects your personal data and consists of the following sections:

Important information and who we are
This privacy policy gives you information about how Athena Security Solutions Ltd collects and uses your personal data through your use of this website, including any data you may provide when you contact us, complete our General Enquiries Form, register with us or engage our services, or when you apply to work for or with us.
This website is not intended for children and we do not knowingly collect data relating to children.

Controller
Athena Security Solutions Ltd is the controller and responsible for your personal data (collectively referred to as " the Company", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

The types of personal data we collect about you

• Personal data means any information about an individual from which that person can be identified.
• We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Dataincludes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Credit History Dataincludes financial and borrowing history data and any other information required to build credit reports.
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.

includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Health Dataincludes data concerning your health, medical conditions or disability, this is special category data and may only be collected from you for use and storage if necessary to providing our services or for the recruitment and the onboarding process.

1. If you are a candidate applying to work for or with us, we may also collect, use, store and transfer personal information about you as grouped below:

• Recruitment Information: copies of right to work documentation, copies of passport or other photo ID, copies of proof of address documentation (for example, bank statement or utility bill), background screening and vetting including credit history, social media/networking presence, references, and information included in a CV (for example, prior employment, education. training or qualifications), or cover letter or as part of the application process or examples of work (for example, written materials, photos, video or audio recordings).
• Employment Status Check Data: results of HMRC employment status check, background or vetting checks and details of your interest in and connection with the intermediary (if any) through which your services are supplied.
• Selection and Assessment Information:information recorded as part of the recruitment process, including candidate selection, profiling and data analytics, interview and assessment information including notes, recordings and transcripts.
• In addition to Health Data, we may also collect, use, store and transfer the following types of more sensitive personal information or special category information during the recruitment process:
• Criminal offences:We may also collect, store and use criminal offence information about you. This is information about criminal convictions and offences, including information about the alleged commission of offences, proceedings for an offence committed (or alleged to have been committed) and the disposal of those proceedings, including sentencing. We will collect information about your criminal convictions history if we would like to offer you a role with us or otherwise work with us (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for working with us. This is especially important due to the industry that we operate in, the security services industry requires a high degree of trust and integrity.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How is your personal data collected?

We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:apply for our products or services;subscribe to our service or publications; request marketing to be sent to you; apply to an advertised vacancy with us, make a speculative application for recruitment, or otherwise engage with any of our recruitment processes and stages; enter a competition, promotion or survey; or give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data is collected from the following parties:
analytics providers such as Google based outside the UK;
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as our bank based inside the UK.
Identity and Contact Data is collected from publicly available sources such as Companies House based inside the UK.
If you are a recruitment candidate, we will also receive personal data about you from various third parties and public sources as set out below
Identity Data, Contact Data and Recruitment Information is collected from parties including education or training establishments, previous employers, recruitment agencies, head-hunters, social media/networking platforms and other third-party platforms.
Selection and Assessment Information is also collected from recruitment agencies and head-hunters.
Identity and Employment Status Check Data is collected from the HMRC.
Criminal offences information is collected from the Disclosure and Barring Service (DBS).

How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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 to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent:We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
1. To register you as a new customer
Type of data: (a) Identity, (b) Contact

Legal basis: Performance of a contract with you

2. To process and deliver your order including:
Sub-purposes: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us

Type of data: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Credit History, (f) Marketing and Communications

Legal basis:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

3. To manage our relationship with you which will include:
Sub-purposes: (a) Notifying you about changes to our terms or privacy policy; (b) Dealing with your requests, complaints and queries

Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications

Legal basis:

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

4. To enable you to complete a survey
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications

Legal basis:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5. To administer and protect our business and this website
Scope: Includes troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.

Type of data: (a) Identity, (b) Contact, (c) Technical

Legal basis:

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

6. To deliver relevant website content and online advertisements to you and measure or understand their effectiveness
Type of data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical

Legal basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)

7. To use data analytics to improve our website, products/services, customer relationships, and experiences
Scope: Also includes measuring the effectiveness of our communications and marketing.

Type of data: (a) Technical, (b) Usage

Legal basis: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)

8. To carry out market research through your voluntary participation in surveys
Type of data: [Not explicitly listed separately in the provided text for this row]

Legal basis: Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

Recruitment Candidate Purposes
(The following are applicable if you are a recruitment candidate only)

9. To carry out our recruitment procedures and assess your suitability for a role with us
Scope: Applies whether as an employee, worker, or self-employed contractor.

Type of data: (a) Identity, (b) Contact, (d) Recruitment Information, (f) Selection and Assessment Information, (g) Health Data, (h) Criminal offences information

Legal basis:

(a) Necessary for our legitimate interests (for running our business, effective provision of our services, business security, to prevent fraud and illegality)

(b) To protect recruitment candidate’s vital interests and safety by assessing their suitability against the requirements of the roles and positions offered by us

(c) Performance of a contract with you in so far as we are contemplating entering into contractual relations

(d) Necessary to comply with a legal obligation if a recruitment candidate has reasonable adjustment or support requirements.

10. To carry out screening, vetting, and onboarding procedures and setting up a candidate record
Scope: Prior to commencing engagement as an employee, worker, or self-employed contractor.

Type of data: (a) Identity, (b) Contact, (c) Financial, (d) Employment Status Check, (e) Criminal offences information

Legal basis:

(a) Necessary for our legitimate interests (for running our business, effective provision of our services, business security, to prevent fraud and illegality)

(b) Necessary to comply with a legal obligation

(c) Performance of a contract with you in so far as we are contemplating entering into contractual relations

11. To communicate with you about the recruitment process
Type of data: (a) Identity, (b) Contact, (f) Marketing and Communications

Legal basis:

(a) Necessary for our legitimate interests (for running our business, effective provision of our services, to keep our records updated and manage our relationship with you)

(b) Necessary to comply with a legal obligation

(c) Performance of a contract with you

12. To consider you for future vacancies and notify you of opportunities that may be of interest to you
Type of data: (a) Identity, (b) Contact, (c) Recruitment Information, (d) Selection and Assessment Information

Legal basis:

(a) Necessary for our legitimate interests (for running our business, effective provision of our services, to keep our records updated)

(b) Consent

Direct marketing and further communications
We do not engage in direct marketing.
For unsuccessful recruitment candidates, if you consent for us to do so, we may retain your Identity, Contact, Recruitment Information, and Selection and Assessment Information, and use such personal data to consider you for future vacancies and notify you of opportunities that may be of interest to you, subject to the data retention period applicable as set out in paragraph 10.
Third-party marketing
We do not share your personal data with any third party for their own direct marketing purposes or their own commercial use.
Opting out of marketing
You can ask us to stop sending you marketing communications (including recruitment marketing communications) at any time by contacting us (see paragraph 10).
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative, or customer service or recruitment purposes for example relating to order confirmations for a product/service, appointment reminders, updates to our Terms and Conditions, hiring and engagement decisions, and checking that your contact details are correct.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please refer to the cookies banner on our website and our cookies policy as updated from time to time.
Disclosures of your personal data
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
External Third Parties such as the HMRC, recruitment agencies, head-hunters, electronic signature platforms, and third party service providers such as IT, payroll, workforce and operations management, recruitment screening/vetting and HR service providers.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

4. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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. We do not sell or share your personal data with any third parties for their commercial use.
International transfers
We do not normally transfer your personal data outside the UK and the EEA.
Whenever we need to transfer your personal data out of the UK and the EEA to countries which have laws that do not provide the same level of data protection as the UK law or EU law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
We may transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.
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. In addition, 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 they 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.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
For recruitment candidates who are unsuccessful and have consented for us to retain their personal data to be considered for future vacancies, we expect to retain the relevant personal data listed under paragraph 4 for up
to twelve months after they have been informed of the outcome of the recruitment process.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "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 personal 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 in certain circumstances. 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 (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies 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 (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see paragraph 10).
If you are based outside of the UK, depending on the country you are based in, you may be entitled to further rights regarding your personal data under the local data protection laws applicable to you.
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. Alternatively, we could 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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you 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 one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: info@athenasecuritysolutions.co.uk
• Postal address: 10a High Street, Chislehurst, Kent, BR7 5AN
• Telephone: 08000206200

Complaints
You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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, for example a new address or email address.
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 our website, we encourage you to read the privacy policy of every website you visit.