PRIVACY STATEMENT

Version 3.0 – 15 March 2023

ABOUT THIS PRIVACY NOTICE

At APC Success we respect your privacy and are committed to protecting your personal data. This ‘privacy notice’ explains how and why we collect, store, use and share personal data and your rights to control our use of it.

It applies not just to use of our websites, but also personal data that we process through other interactions with individuals in the course of running our organisation and fulfilling our mission, such as our members, partner organisations, suppliers, sponsors, industry contacts and people interested in working for or with us. We maintain a separate privacy notice that will apply if we engage with you as an employee or consultant/contractor.

INFORMATION ABOUT US AS DATA CONTROLLER

This privacy notice is for the Hillbreak Limited (“Hillbreak”) and Hillbreak (APC Success) Limited (“APC Success”) (together referred to hereinafter as “we”, “us”, or “our”). Our details are:

  • Hillbreak Limited (registered in England & Wales with registered number 9619492)
  • Hillbreak (APC Success) Limited (registered in England & Wales with registered number 10568488)

We collect, use and are responsible for certain personal data. When we do so we are regulated under data protection laws and we are responsible as “data controller” of that personal information for the purposes of the law.

The best way to contact us is by email at [email protected] or [email protected]. Our postal address is PO Box 372, ORMSKIRK L40 3XD.

TYPES OF PERSONAL DATA OBTAINED, PURPOSES AND LEGAL BASIS

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect and use personal data from different categories of individual for different purposes and these each have a ‘lawful basis’. This section describes the lawful basis and purposes in detail and, although it’s technical, we’re required by law to explain this to you.

If you receive our email newsletter or updates: we will hold your email address for the purpose of sending you updates on APC Success, our courses and services, industry news and subject-relevant analysis. We process this data on the basis that we have your consent. You can withdraw your consent at any time by using the “unsubscribe” links at the bottom of each email. We will hold that data until you unsubscribe or your email address becomes undeliverable.

If you work for a client or partner organisation, or if you are an industry contact: we may hold your name, company, job title and contact details. We will have been provided with this data by you or your employer or in some cases we may have sourced it from publicly available sources, such as Linked In and internet searches. We need this data in order to interact with you (or your employer) for the following purposes:

  • To operate our services for clients
  • To promote and grow our business
  • To communicate with interested people regarding events, news and updates
  • To gather and disseminate information and share knowledge relevant to our mission

We do this on the basis that it is necessary for our legitimate interests in operating our business and providing training and consultancy services. We will hold your details for as long as we need to interact with you for these purposes. If you would like us to update or delete your information, please send us an email.

If you have an account on our Learning Hub training platform: we will hold your name, email address, job title, company and image for the purpose of providing you with secure access to the platform and operating the platform so that you can access the information and training materials and participate in training. We process this data on the basis that it is necessary for our legitimate interests in providing training services. You or your employer will have provided us with these details. If you no longer require your account please email us. We will hold your information until your access to the platform is withdrawn.

If you are a member of any of our Training Groups: we will hold your name, company, job title and contact details and in some cases we may also ask for details such as dietary preferences or access requirements. This is for the purpose of operating the Training Group in accordance with its terms, which may be in-person or online. We do this on the basis that it is necessary for our legitimate interests in operating a training services business. Your data may be shared with or visible to the other Training Group members and attendees at Training Group meetings. You or your company will have provided us with these details. If you would like us to update or delete your information, please send us an email.

If you are a supplier or work for a supplier: we may hold your name and contact details in order to interact with you or your employer to procure and pay for goods and services. We do this on the basis that it is necessary for our legitimate interests in doing business with you or your company. We will hold this information for as long as we need to interact with you for these purposes. If you would like us to update or delete your information, please send us an email.

If you submit an application to work for us, whether as an employee or consultant/contractor: we will hold any personal information you provide to us (via our website or other methods), or that is sent to us by a third-party recruitment agency or website. This is likely to be your name, contact details, CV and other information relevant to your skills, experiences and interests (such as content portfolios). We will use this information for the purpose of communicating with you and evaluating your application. We do this on the basis that it is necessary for our legitimate interests in recruiting talented people in order to operate our business and deliver services to clients. We will hold this information for as long as we need to interact with you for these purposes and the data of unsuccessful candidates will normally be deleted no more than 12 months after a decision is made. In all cases if you would like us to update or delete your information, please send us an email.

COOKIES AND SIMILAR TECHNOLOGIES

If you visit our website, we may store information relating to you using cookies or similar technologies, which we can access when you visit our site in future.

Generally, the cookies used do include information from which you can be identified as an individual.  For more information on our use of cookies and how to control them see our Cookies Pop-Up bar that appears when you first visit our site.

RETENTION OF PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, taking into account applicable data protection laws, retention periods under applicable laws, limitation periods and our business needs.

SHARING YOUR PERSONAL DATA

We may share your personal data with the following third parties in certain circumstances:

  • IT and system administration service providers acting as data processors (see below) who provide services or cloud-based software to enable us to operate our organisation.
  • Professional advisers such as lawyers, bankers, accountants or auditors in order to provide legal, finance, accounting or auditing services.
  • Law enforcement or other authorities (such as tax authorities) if required by applicable law.

If you attend one of our events, the name and company of attendees are usually shared with the event speakers, any third-party event hosts and may be shared with other attendees. This is done to support meeting administration, share knowledge and enable access to the venue.

We reserve the right to disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.

Data processors: We use a number of different service providers (acting as ‘data processors’) who provide IT and system administration services to enable us to operate our organisation and the services we provide. Your personal data is transferred to (and stored by) these data processors, who generally fall under the following categories:

  • Website analytics
  • Website and data hosting
  • IT and system administration
  • Document storage
  • Email, contacts and calendar
  • CRM, accounting and billing

These ‘data processors’ only process data on our behalf. They won’t use your personal data for their own purposes and we only permit them to use it in accordance with our instructions, our contract with them and the law.

For security reasons we do not name all our service providers in this privacy notice. Please contact us (see below) if you want further information on specific data processors or the types of personal data they process for us.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We do not normally process personal data outside the UK or the European Economic Area (EEA), except when dealing with clients or consultants located outside that area.  Also, some of our data processors may do so and this section explains the impact of these international transfers and how your information is protected.

Many of our data processors operate “cloud-based systems”, which means the information is held in information data centres in different locations. In some cases, they hold copies of your personal information outside the UK/EEA. In each such case our processors and/or we employ one or more of the transfer safeguard mechanisms designated by data protection legislation, which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of abuse.

Please contact us (see above) if you want further information on the specific mechanisms used by our data processors when transferring your personal data out of the UK/EEA.

YOUR PERSONAL DATA RIGHTS

The personal data we hold about you is your data, and you have certain rights over the data under applicable data protection laws. This section summarises the rights you have where your personal data is protected under UK data protection legislation.

  • You have the right to request a copy of all personal data we hold relating to you. You also have the right to require us to correct any mistakes in the personal data we hold relating to you.
  • Where we are processing your data based on your consent you can withdraw that consent and we must immediately stop processing your data.
  • Where we process your data based on a “legitimate interest” (underlined in the section on “purpose and legal basis”, above) you still have the right to object to our processing of that data if you feel it impacts on your fundamental rights and freedoms.
  • You also have the right to object where we are processing your personal data for direct marketing purposes. The easiest way to do this is to use the unsubscribe links at the bottom of all marketing emails.
  • In certain situations, you have the right to require us to erase personal data where there is no good reason for us continuing to process it, or to request restriction of processing of your personal data.
  • Finally, you have the right to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format in certain circumstances.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, the easiest way is by dropping us an email (see above).

AUTOMATED DECISION-MAKING USING PERSONAL DATA

You have a right to object to any decisions being taken through the processing of your personal data by automated means if they produce legal effects concerning you or similarly significant effects on you. We can confirm that we do not undertake any automated decision-making, or profiling, based on the processing of personal data.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, 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 care and confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

YOUR RIGHTS TO LODGE A COMPLAINT WITH THE REGULATOR

At all times, you have the right to report a concern or lodge a complaint with the Information Commissioner’s Office. Please refer to the ICO at https://ico.org.uk/concerns/ or by calling them on 0303 123 1113. Of course, we hope that we can resolve your issue quickly and fairly ourselves.

CHANGES TO THIS PRIVACY NOTICE

This privacy notice was last updated on 15 March 2023. We may change this privacy notice from time to time by amending this page.