Who we are
For the purpose of applicable data protection laws, the data controller is:
CA Group Limited
Evenwood Industrial Estate
Telephone: 01388 834242
Information Covered by this Policy
This policy covers all personal information collected and used by UPA (UK) Limited. In this policy "personal information" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly.
General Principles of UPA (UK) Limited’s Collection, Use and Disclosure of Personal Information
Whenever we collect personal information UPA (UK) Limited will:
- provide timely and appropriate notice to you about our data practices
- collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purpose it is collected
- process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented
- take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete and, where necessary kept up to date
- not use your personal information for direct marketing purposes with giving you an opportunity to opt out
- take appropriate measures by contract, or otherwise, to provide adequate protection for personal information that is disclosed to a third party by necessity to fulfil contractual obligations
Personal Information UPA (UK) Limited Collects
We may collect the following types of personal information from different sources detailed below:
Information you provide:
- Contact information such as name, company name, address, email address and telephone number
- Financial information needed to process payments if you make purchases, such as credit card or account information or tax identification references
- Information about your preferences, such as your preferred methods of communication
Information we collect about you:
When someone visits www.upa-uk.com we use a third party service, Google Analytics, to collect internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it. For more information on how Google collect and use data when you visit our website please visit: www.google.com/policies/privacy/partners/.
UPA (UK) Limited’s lawful basis for processing your personal data
Processing on the basis of legitimate business interests.
When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting UPA (UK) Limited’s internet sites, products, and services; (ii) communicating with current and potential customers, other Business Partners, and their individual points of contact; (iii) managing our relationships with our customers and other Business Partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within UPA (UK) Limited, as well as with service providers and other third parties as required by law; and (vi) maintaining the safety and security of our products, services and employees, including fraud protection.
Processing on the basis of performance of a contract.
Examples of situations in which we process personal information as necessary for performance of a contract include material supply contracts and installation contracts in which you purchase a product or service from UPA (UK) Limited.
Processing on the basis of consent.
Examples of processing activities for which UPA (UK) Limited uses consent as its legal basis include: (i) sending promotional emails when consent is required under applicable law; and (ii) processing personal data on UPA’s internet sites through cookies and similar technologies when consent is required by applicable law.
Processing because UPA (UK) Limited is under a legal obligation to do so.
Examples of situations in which UPA (UK) Limited must processes personal data to comply with its legal obligations include: (i) payment of taxes and other government levies; (ii) providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records that are required to be retained by applicable laws; and (iv) complying with court orders or other legal process.
Additional information about the retention of your personal data
To determine the period for which your personal data will be retained in accordance with this Policy, UPA (UK) Limited considers criteria such as: (i) any applicable legal requirements to retain data for a certain period of time; (ii) any retention obligations related to actual or potential litigation or government investigations; (iii) any retention requirements in relevant agreements with our Business Partners; (iv) the date of your last interaction with UPA (including with websites, communications, etc.); (v) the length of time between your interactions with UPA; (vi) the sensitivity of the data; and (vii) the purposes for which the data was collected.
Your individual rights
In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. You can exercise your rights by sending your request to us at firstname.lastname@example.org.
For further information on your rights regarding your data visit the ICO website at https://ico.org.uk/
Access to personal information
In accordance with GDPR, UPA (UK) Limited will be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘Subject Access Request’ under the General Data Protection Regulation. If we do hold information about you we will:
- give you a description of it
- tell you why we are holding it
- tell you who it could be disclosed to
- let you have a copy of the information in an intelligible form
If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request.
For further information on how to request your personal information go to the ICO website at https://ico.org.uk/for-the-public/personal-information/.
UPA (UK) Limited will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country where you live. The overall competent supervisory authority for UPA (UK) Limited in Europe is:
Information Commissioner's Office (ICO)
CA Group Limited, on behalf of UPA (UK) Limited is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at email@example.com.
What will we do with the information you provide to us?
All of the information you provide during the recruitment process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
We might ask you to complete tests and/or to attend an interview. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by UPA (UK) Limited.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a specified period of time. If you say yes, we would proactively contact you should any further suitable vacancies arise.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer.
We are required to confirm the identity of our staff and their right to work in the United Kingdom. You will therefore be required to provide:
- Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments
- Emergency contact details – so we know who to contact in case you have an emergency at work
Final Offer & Commencement of Employment
If you accept a final offer from us, your personnel records will be held on our secure HR system which is an internally used HR records system.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus a specified period of time following the end of your employment.
If you are unsuccessful at any stage of the process, the information you have provided until that point including information generated throughout the assessment process, for example interview notes, will be retained for a specified period of time from the end of the recruitment process for that position.
Security and performance
UPA (UK) Limited uses a third party service to help maintain the security and performance of the UPA (UK) Limited website. To deliver this service it processes the IP addresses of visitors to the website.
We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
This Policy was last revised 22nd May 2018.