Procuring Limited (“Procuring”) is a professional services company based in the United Kingdom. We are committed to safeguarding the privacy of the personal information that is provided to us or collected by us during the course of our business as well as the personal information we receive from visitors to our Procuring websites (www.procuringgroup.com and www.procuringgroup.co.uk) and any associated websites under our control (together our “Websites”). Procuring is the data controller of any personal information provided to us when we agree to provide services to you as described below.
Business development and business acceptance
We collect personal information about prospective clients and their beneficial owners, controllers and/or directors as part of business development initiatives and our business acceptance process. The type of personal information we may collect includes name, address, nationality, business interests and employment history. We obtain this information from publicly available open sources either directly or through a third party.
Professional services and keeping you up to date with relevant marketing
The type of personal information that we may collect includes current and historical information including your name and contact details (such as your address, email address and telephone numbers) and identifiers such as your organisation, employment history and positions held. We will also collect personal information you choose to provide to us directly, or, for example, through your use of our Apps or other online services, and information about your other dealings with us and our clients, including contact we have with you in person, by telephone, letter, email or online. This information may include access or dietary requirements which may reveal information about your health or religious beliefs. We obtain personal information from your IP address and the operating system and web browser that you use to access our Websites. It enables us to identify which organisations have visited our Websites and we use this information to compile statistical data on the use of those sites to help us to improve the user experience.
We collect personal information directly from you, from our clients or other parties to a matter and their authorised representatives. We may also collect personal information from third parties such as your employer, other organisations that you have dealings with, regulators, government agencies, credit reporting agencies, publicly available records (including electronic data sources to carry out checks to enable us to comply with applicable law), information or service providers (some of whom may process your personal information on our behalf), recruitment agencies and other professional advisers. Your personal information may be collected in our contact database when you register to receive updates or we otherwise receive your contact details.
We use a third-party service provider to manage the our contact database and deliver emails to inform you about our services, industry developments and updates and invite you to events (including those we may jointly host with other organisations).
You can control the information you receive through our direct marketing function by using the “Managing your preferences” option at the bottom of the emails. If you no longer wish to receive marketing emails relating to our services by email or post, you can unsubscribe at any time by using the “Unsubscribe” option on the email footer.
If you apply for a role or work experience opportunity, open day or insight event at Procuring we will collect personal information directly from you, or from recruitment agencies, recruitment websites and apps or other third parties involved in our recruitment and screening process. These third parties include service providers that we use to store this information or help us to contextualise the information, where relevant, and also screening check providers, providers of occupational personality tests, health service providers, professional associations, government and law enforcement agencies, referees and your current and previous employers.
We will use this information to consider your application for a position with Procuring (with the exception of the information provided in the Equal Opportunity and Diversity section which will be used for statistical purposes (internally and via external providers) to help us better support a diverse and inclusive workplace and meet our regulatory and legal requirements). We will also use the information to process additional information about you through carrying out checks to verify the information provided by you (including reference, background, identity, suitability and criminal record checks).
In order to use your personal information we need a lawful basis to do so. We rely on the fact that using your personal information in this way is necessary for our legitimate interest in hiring appropriately skilled employees and running an effective recruitment process. We may also rely on the condition that we need to perform our obligations in a contract with you, for example if you have signed an employment contract with us but have yet to join the company. In some circumstances, such as meeting visa requirements, we have a legal obligation to use your personal information. If we need to process special categories of personal data or use any criminal offence information about you to conduct criminal background checks as part of our pre-employment screening exercise, we and/or our third-party provider will ask for your consent, if necessary.
We will only use your personal information if and to the extent that applicable law allows. We will therefore only process your personal information if:
We may use your personal information to:
We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. Personal information processed in connection with our business acceptance processes and/or providing legal services will be retained in accordance with the our retention and destruction policy unless we agree otherwise with you, in writing.
We may share your personal information with our offices, branches, in-house companies due to, for example, our shared IT systems and/or cross jurisdictional working on a matter. We use third-parties who provide services on our behalf and will share your information with them, for example a technology supplier may have access to your personal information when providing software support, or a company we use for a communications campaign may process the personal information of our contacts for us.
During the course of working with you or the organisation you work for we may use certain third-party technology services to assist with our work on the matter. Where these services are integral to our work for you (for example, the use of word processing software provided by Microsoft), we deploy them as a matter of course. We also use various ancillary services, for example, software that is capable of effecting bulk data transfers or facilitating e-signatures and virtual completions. In all cases, the use of such services may require your personal information to be held in the cloud.
We may also have to share your personal information with regulators, government agencies, courts and other third parties.
Your personal information may be accessed by these offices, branches, in-house companies and third-parties in countries whose laws provide varying levels of protection for personal information. As set out above, some of your personal information may be stored in a cloud located within or outside of the European Economic Area (the EEA) and managed by a third-party service provider. Where we transfer your personal information outside the EEA we will take reasonable steps to ensure that your information is treated securely and the means of transfer provide adequate safeguards.
Personal information shared between our offices will be subject to the contractual obligations imposed by EU standard contract clauses.
We may share your personal information with third parties where:
We use up to date data storage and security to hold your personal information securely in electronic and physical form to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. Our premises are access controlled and our electronic databases require logins and password authentication.
All our directors, staff and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
However, the transmission of information via the internet is not completely secure. Although we take appropriate and proportionate steps to manage the risks posed, we cannot guarantee the security of your information transmitted to our online services.
Our Websites contain links to other sites which are controlled by third parties, for example social networks. You should review these other sites’ privacy policies. We do not accept any responsibility for their use of your personal information.
You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold.
These rights are to:
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once Procuring has received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you would like to exercise any of these rights, please contact Procuring in writing by emailing email@example.com or by letter to:
No 1 Spinningfields
If you have any questions about this policy or how we handle your personal information, please contact the Privacy Department as set out above.
We hope that our Privacy Department can resolve any query or concern you raise about our use of your personal information. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at ico.org.uk/concerns or telephone 0303 123 1113.