Privacy policy

Axion privacy and fair processing notice

May 2018

Your guide to how we handle personal data (information that could identify you).
To ask us what personal data we hold on you, email info@axiongroup.co.uk or call +44 161 426 7731.

If you have any complaints about how we have treated your personal data you can contact the UK Information Commissioner at https://ico.org.uk/

This privacy policy addresses the following:

  • Business contacts and enquirers
  • Customers
  • Former customers
  • Suppliers and potential suppliers
  • Newsletter subscribers
  • Employees, previous employees and subcontractors (current and previous)
  • Candidates for job vacancies
  • Website use

 

  • Business contacts and enquirers

Note that this section of the policy only applies before any order is made. See customers for details of how we handle customer personal data.

Data controller
Axion Recycling Ltd.

What data we collect
We collect names, contact details and job titles of people who might be interested in our products and services. We may, with your consent, take photographs and video recordings. We may also hold photographs of you taken before May 2018 for which you did not give explicit consent.

Where we collect data from
We collect data directly from people who contact us with enquiries and from people we meet or make contact with in other ways. We also collect data indirectly from publicly available sources and from third-party individuals who may tell us about people who might be interested in our services.

How we use personal data
We use your contact details to give you information about our products and services. We respond to specific enquiries and may also contact you if we develop a new service or product you might be interested in.

We also use personal data to communicate in relation to potential and existing collaborative projects and activities.

We may use photographs and video recordings of you for promotional purposes.

Who we share personal data with
We share business contact and enquirer personal data with third-party organisations who provide services to support the operation of our business, including suppliers of cloud-based software. These third parties may in turn share personal data with other companies acting as sub-processors. The organisations we share your data with include (but are not limited to) our website and email hosts and IT support providers, and providers of cloud-based office administration, document storage and bookkeeping software, email marketing services, and CRM (customer relationship management) services.

Third-party providers are subject to change. You can ask us for current details by emailing info@axiongroup.co.uk or calling +44 161 426 7731

We may also share photographs and video recordings of you with the public in our promotional material.

We may also, with your agreement, share personal data with other companies we partner with to provide products and services.

Otherwise, we only share your data with other organisations as required by law.

How we protect personal data
We apply high levels of security to data stored on our own servers and provide appropriate data protection training for staff. Where we share information with third parties either within the European Economic Area or outside it, we use our best efforts to ensure each organisation is committed to high standards of data security and complies with GDPR.

The organisations we share personal data with have agreed to use it only for the purposes of helping us operate our business or as required by law.

We are working towards the UK government’s Cyber Essentials accreditation to ensure we are doing everything possible to keep data safe.

Legal basis for handling personal data for enquirers and business contacts
The legal basis on which we handle personal data for enquirers and business contacts is legitimate interest. The legitimate interest is that of responding to enquiries and marketing our business.

How long we keep personal data
We will keep your personal data for as long as we think you might have an interest in our products and services.

What to do if you want us to delete your personal data or to stop contacting you
If you want us to delete your personal data, email info@axiongroup.co.uk or call +44 161 426 7731.

If you do not want us to contact you again in future, email info@axiongroup.co.uk or call +44 161 426 7731. We will keep a note of your name and company so that we know not to contact you.

What to do if you want us not to use photographs or video recordings of you
To ask us not to use photographs or video recordings of you, email info@axiongroup.co.uk or call +44 161 426 7731.

 

  • Customers doing business with us on and after 25 May 2018

Data controller
Axion Recycling Ltd

What data we collect
We collect names, contact details and job titles of people who buy our products and services.

We collect bank details which may be personal data if they belong to an individual sole trader rather than a company. We also obtain both credit reports and trade references that may contain personal data.

We may, with your consent, take photographs and video recordings of you. We may also hold photographs of you taken before May 2018 for which you did not give explicit consent.

Where we collect data from
We collect data directly from people who contact us to buy our products and services. We also collect data from publicly available sources, trade referees, credit checking agencies, and third-party individuals who may tell us about potential customers.

How we use personal data
We use your personal data to give you information about the products and services you are buying, to undertake due diligence before entering into contracts, to process orders, to deliver the product or service, and to obtain payment.

We may also use your details to contact you if we develop a new service or product you might be interested in, or to discuss potential and existing collaborative projects and activities.

We may use photographs and video recordings of you for promotional purposes.

Who we share personal data with
We share customer personal data with third-party organisations who provide services to support the running of our business, including suppliers of cloud-based software. These third parties may in turn share personal data with other companies acting as sub-processors. The organisations we share your data with include (but are not limited to) our bank, our accountant, our website and email hosts, our IT support providers, and providers of cloud-based office administration, document storage and bookkeeping software, email marketing services, and CRM (customer relationship management) services. We may share personal data with relevant third parties for the purposes of debt collection.

Third-party provider details are subject to change. You can ask us for current details by emailing info@axiongroup.co.uk or calling +44 161 426 7731

We may also share photographs and video recordings of you with the public in promotional material.

We may, with your agreement, share personal data with other companies we partner with to provide our products and services.

Otherwise, we only share data with other organisations as required by law.

How we protect personal data
We apply high levels of security to data stored on our own servers and provide appropriate data protection training for staff. Where we share information with other organisations either within the European Economic Area or outside it, we use our best efforts to ensure each organisation is committed to high standards of data security and complies with GDPR guidelines.

The organisations we share personal data with have agreed to use it only for the purposes of helping us operate our business or as required by law.

We are working towards the UK government’s Cyber Essentials accreditation to ensure we are doing everything possible to keep data safe.

Legal basis for handling personal data for customers
For most activities involving customers, the legal basis on which we handle personal data for customers is contract. We may also rely on the legal basis of legitimate interest where we use data to market our business.

How long we keep personal data
We will keep your personal data for as long as is necessary to deliver the service and then for 7 years. We may also keep your data for as long as we think you might be interested in buying further products and services from us.

What to do if you want us to delete your personal data or to stop contacting you
If you want us to delete your personal data, email info@axiongroup.co.uk or call +44 161 426 7731. We will let you know whether it is possible to delete your data. We can’t delete data that must be kept for tax and accounting purposes.

If you do not want us to contact you again in future, email info@axiongroup.co.uk or call +44 161 426 7731. We will keep a note of your name and company so that we know not to contact you.

What to do if you want us not to use photographs or video recordings of you.

To ask us not to use a photograph or video recording of you, email info@axiongroup.co.uk or call +44 161 426 7731.

 

  • Customers who have not done business with us since before 25 May 2018

What data we hold
We hold names, contact details and job titles of people who have bought our products and services.

We hold bank details which may be personal data if they belong to an individual sole trader rather than a company plus information gathered in the course of preparing to do and doing business with you. This includes publicly available data, credit check reports, trade references, and information from third-party individuals.

We may hold photographs and videos of you that were taken with your consent. We may also hold photographs taken before 25 May 2018 for which you did not give explicit consent.

Where we collect data from
We collect data directly from people who contact us to buy our products and services. We also collect data indirectly from publicly available sources, credit agencies, trade referees and third-party individuals who may tell us about potential customers.

How we use personal data
We use your contact details to give you information about products and services we develop that we think might interest you. We may also contact you about potential collaborative projects and activities.

We may use personal data for any remaining activities associated with the business you did with us, including debt collection.

We may also use photographs and videos of you for promotional purposes.

Who we share personal data with
We share customer personal data with third-party organisations who provide services to support the running of our business, including suppliers of cloud-based software. These third parties may in turn share personal data with other companies acting as sub-processors. The organisations we share your data with include (but are not limited to) our bank, our accountant, our website and email hosts, our IT support providers, and providers of cloud-based office administration, document storage and bookkeeping software, email marketing services, and CRM (customer relationship management) services. We may share personal data with relevant third parties for the purposes of debt collection.

We may also share photographs and video recordings of you with the public in promotional material.

We may, with your agreement, share personal data with other companies we partner with to provide our products and services.

Third-party provider details are subject to change. You can ask us for current details by emailing info@axiongroup.co.uk or calling +44 161 426 7731.

Otherwise, we only share data with other organisations as required by law.

How we protect personal data
We apply high levels of security to data stored on our own servers and provide appropriate data protection training for staff. Where we share information with other organisations either within the European Economic Area or outside it, we use our best efforts to ensure each organisation is committed to high standards of data security and complies with GDPR guidelines.

The organisations we share personal data with have agreed to use it only for the purposes of helping us operate our business or as required by law.

We are working towards the UK government’s Cyber Essentials accreditation to ensure we are doing everything possible to keep data safe.

Legal basis for handling personal data for former customers
For most activities involving customers, the legal basis on which we handle personal data for customers is contract. We may also rely on the legal basis of legitimate interest where we use data to market our business.

How long we keep personal data
We will keep your personal data for 7 years from the date we last did business together. We may also keep your data for as long as we think you might be interested in buying further products and services from us.

What to do if you want us to delete your personal data or to stop contacting you
If you want us to delete your personal data, email info@axiongroup.co.uk or call +44 161 426 7731. We will let you know whether it is possible to delete your data. We can’t delete data that must be kept for tax and accounting purposes.

If you do not want us to contact you again in future, email info@axiongroup.co.uk or call +44 161 426 7731. We will keep a note of your name and company so that we know not to contact you.

What to do if you want us not to use photographs or video recordings of you
To ask us not to use photographs or video recordings of you, email info@axiongroup.co.uk or call +44 161 426 7731.

 

  • Suppliers and potential suppliers

Data controller
Axion Recycling Ltd

What data we collect
We collect names, contact details and job titles of people from organisations who supply products and services to us, who we might want to buy from in future, or who we might recommend as suppliers to our customers.

We may, with your consent, take photographs and video recordings. We may also hold photographs taken before May 2018 for which you did not give explicit consent.

Where we collect data from
We collect data directly from people who approach us or who we meet or make contact with in other ways. We also collect data from publicly available sources, trade referees, and third-party individuals who may tell us about potential suppliers.

How we use personal data
We use your contact details to contact you about your products and services, to conduct due diligence before entering into a contract, and to communicate about orders and potential and existing collaborative activities.

We may use photographs and video recordings for marketing purposes.

Who we share personal data with
We share supplier and potential supplier personal data with third-party organisations who provide services to support the running of our business, including suppliers of cloud-based software. These third parties may in turn share personal data with other companies acting as sub-processors. The organisations we share your data with include (but are not limited to) our bank, our accountants, our website and email hosts, our IT support providers, and providers of cloud-based office administration, document storage and bookkeeping software, email marketing services, and CRM (customer relationship management) services.

We may share data with relevant parties when we undertake due diligence.

We may also share photographs and video recordings of you with the public in promotional material.

Third-party provider details are subject to change. You can ask us for current details by emailing info@axiongroup.co.uk or calling +44 161 426 7731

We may also, with your agreement, share personal data with other companies we partner with to provide our products and services and with potential customers for your services.

Otherwise, we only share data with other organisations as required by law.

How we protect personal data
We apply high levels of security to data stored on our own servers and provide appropriate data protection training for staff. Where we share information with other organisations either within the European Economic Area or outside it, we use our best efforts to ensure each organisation is committed to high standards of data security and complies with GDPR guidelines.

The organisations we share personal data with have agreed to use it only for the purposes of helping us operate our business or as required by law.

We are working towards the UK government’s Cyber Essentials accreditation to ensure we are doing everything possible to keep data safe.

Legal basis for handling personal data for suppliers
For most activities involving suppliers and potential suppliers, the legal basis on which we handle personal data is contract. We may also rely on the legal basis of legitimate interest where we use data to promote the scheme or to contact you for reasons that do not form part of our contractual obligation.

How long we keep personal data
We will keep your personal data for as long as is necessary to for you to deliver the service and for 7 years after. We may also keep your data for as long as we think we might be interested in buying further products and services from you.

What to do if you want us to delete your personal data or to stop contacting you
If you want us to delete your personal data or email info@axiongroup.co.uk or call +44 161 426 7731. We will let you know whether it is possible to delete your data. We can’t delete data that must be kept for tax and accounting purposes.

If you want us not to contact you again in future, email info@axiongroup.co.uk or call +44 161 426 7731. We will keep a note of your name and company so that we know not to contact you.

What to do if you want us not to use photographs or video recordings of you
To ask us not to use photographs or video recordings of you, email info@axiongroup.co.uk or call +44 161 426 7731.

 

  • Newsletter subscribers

Note that this policy only applies to the data we collect when you subscribe to the newsletter. If you are also in contact with us in another capacity, we will process separately the details we have for you in that capacity.

Data controller
Axion Recycling Ltd

What personal data we collect
We collect names, email addresses and company names.

How we use personal data
We use your name, email address and company name to send you our newsletter, which contains information about our activities, products and services and about issues related to the circular economy.

Who we share personal data with
We share newsletter subscriber personal data with third-party email marketing software providers who act as data processors in helping us send out our newsletter. In providing services to us, the third-party provider may share personal data with other companies acting as sub-processors.

The providers we use are subject to change. You can ask us for current details by emailing info@axiongroup.co.uk or calling +44 161 426 7731

Otherwise, we only share personal data from our email list with other organisations as required by law.

How we protect personal data
We apply high levels of security to data stored on our own servers and provide appropriate data protection training for staff. Where we share information with other organisations either within the European Economic Area or outside it, we use our best efforts to ensure each organisation is committed to high standards of data security and complies with GDPR guidelines.

We are working towards the UK government’s Cyber Essentials accreditation to ensure we are doing everything possible to keep data safe.

Legal basis for handling personal data for newsletter subscribers
The legal basis on which we handle personal data for people who sign up for our newsletter is consent.

How long we keep personal data
We will keep your personal data until you tell us to delete it. We may also delete email addresses if emails to the address become undeliverable.

What to do if you want us to stop contacting you
If you want us to stop sending you the newsletter, click the unsubscribe link at the bottom of any Axion newsletter.

If you do not want us to contact you in future as part of our wider business development activity, email info@axiongroup.co.uk or call +44 161 426 7731.

What to do if you want us to delete your personal data
If you want us to delete your personal data, email info@axiongroup.co.uk or call +44 161 426 7731.

If you also want us not to contact you in future, let us know using the same contact details. We will keep a note of your name and company so we know not to approach you.

 

  • Employees, previous employees and subcontractors (current and previous)

Data controller
Axion Recycling Ltd.

What data we process
We process names, contact details, nationality, passport, next of kin/emergency contact, work visa and date/place of birth details, job titles, social media account information, bank details, NI numbers, past employment details, contract and salary details, current employment record details, review notes, education and training details, health records, notes from disciplinary actions, notes from redundancy notices, criminal record details, CVs and letters of application, notes from job interviews, details of time off, maternity and paternity leave details, information on family, lifestyle and social circumstances, and equal opportunities monitoring information.

We may, with your consent, take photographs and video recordings. We may also hold photographs taken before May 2018 for which you did not give explicit consent.

Where we collect data from
We collect data directly from you. We also collect data indirectly from publicly available sources such as social media accounts. We may also collect data from background check providers, from other employees and sub-contractors, and from third party individuals such as previous employers.

Why we process personal data
We process data to enter into an employment contract with you and to meet our obligations under that contract, to ensure we are complying with legal obligations, as part of our legitimate interests in running our business, and to protect your vital interests.

We will only rely on our legitimate interests as a reason for processing data where we have concluded that our interests are not overridden by the rights and freedoms of employees or workers.

Information on health conditions counts as a special category of personal data. We process this data to carry out our legal obligations as an employer and for the purposes of assessing the working capacity of the individual.

Processing data allows us to:

  • Communicate internally
  • Manage recruitment and sub-contractor procurement processes
  • Manage workforce activity and schedules
  • Ensure effective general HR and business administration
  • Provide people with the correct pay and benefits and give required information to HMRC
  • Maintain up-to-date records including records of contractual and statutory rights
  • Maintain up-to-date details of who to contact in case of emergency
  • Operate disciplinary and grievance processes to ensure acceptable conduct within the workplace
  • Manage individual performance and plan for career development and succession planning
  • Manage the workforce effectively to ensure sound business performance
  • Operate effective absence and absence management processes to ensure individuals are fulfilling their duties under their contract
  • Operate maternity, paternity, sickness and compassionate leave processes
  • Get occupational health advice and comply with duties in relation to people with medical conditions and disabilities
  • Meet legal obligations including compliance with employment, health and safety, and anti-discrimination laws
  • Respond to and defend against legal claims
  • Maintain and promote equality in the workplace
  • Provide references on request

We may also use photographs and video recordings for promotional purposes.

We do not make employment decisions based solely on automated decision-making.

Who we share personal data with
We share employee, worker and sub-contractor personal data with colleagues, clients, potential clients and suppliers. We may make names and contact details publicly available on our website or in other promotional material. We may share personal data with third parties to obtain references and perform pre-employment checks.

We also share personal data with our website/email service host, our accountants, employment lawyers, HR advisors, payroll providers, bank and IT support providers.

We share data with third party cloud software providers acting as data processors in helping us operate our business. In providing services to us, these third parties may share personal data with other companies acting as sub-processors. Third party software suppliers we use in processing your data include (but are not limited to) providers of office administration and email software, bookkeeping software, and HR management services.

We may also share your data with third parties in the context of a sale of some or all of the business.

External providers are subject to change. You can ask us for current details by speaking to Judith Clayman in HR, emailing info@axiongroup.co.uk or calling +44 161 426 7731

Otherwise, we only share data with other organisations as required by law (with the exception of photographs and video recordings used for promotional purposes).

How we protect personal data
Where we share information with colleagues, clients, potential clients and suppliers, this is limited to the information necessary for the purposes of the business activity involved.

Where data is stored on our own servers, we apply high levels of security and store data in files to which only relevant and authorised staff have access. We store paper-based information in locked filing cabinets to which only relevant and authorised staff have access. Where staff have data stored on company mobile phones or access to data via a company mobile phone, the phone is password protected.

We provide appropriate data protection training for staff.

Where we share information with third party organisations acting as data processors for us either within the European Economic Area or outside it, the third parties are organisations committed to GDPR compliance and to high standards of data security. They act according to agreed instructions, and are under a duty of confidentiality.

We are working towards the UK government’s Cyber Essentials accreditation to help us make sure we are doing everything possible to keep data safe.

Where we share personal data in other contexts, the sharing is subject to confidentiality agreements.

How long we keep personal data
We keep data for as long as you are working for us. When you stop working for us we will delete your data from our IT systems and from our payroll software. We will delete your work mobile phone number. We may still hold emails containing your personal data until individuals delete these when they judge they are no longer required. We will keep hard copy records of your contract of employment, CV, letters of application and notes from interviews indefinitely.

What happens if you do not provide personal data
We can’t enter into an employment contract unless you give us certain information including contact details, payment details and evidence of the right to work in the UK. If you do not give us other information we ask for, we will not be able to administer the rights and obligations of the employment relationship effectively.

You have obligations under your employment contract to give us certain information, and you may be required to give information about disciplinary and other matters under the implied duty of good faith.

You may also need to give us data so we can allow you to exercise statutory rights such as leave entitlements.

Your rights
You have a number of rights as a data subject. You can:

  • Obtain a copy of the data we hold on you
  • Require us to change data that is wrong
  • Require us to delete or stop processing data, for example, where we no longer need the data, or if you don’t want us to use a photo or video recording of you
  • Object to the processing of your data where we are relying on our legitimate interests as the legal basis for processing
  • Ask us to stop processing your data for a period of time if there is a dispute about whether or not your interests override our legitimate grounds for processing the data
  • To exercise any of these rights, speak to Judith Clayman in HR, email info@axiongroup.co.uk or call +44 161 426 7731.

 

  • Candidates for job vacancies

Data controller
Axion Recycling Ltd.

What data we process
We process names, contact details, nationality, passport, work visa and date/place of birth details, job titles, social media account information, employment details, salary and related details, education and training details, health information, criminal record details, CVs and letters of application, notes from job interviews, photographs and equal opportunities monitoring information.

Where we collect data from
We collect data directly from you. We also collect data indirectly from publicly available sources such as social media accounts. We may also collect data from background check providers, from other employees and sub-contractors, and from third party individuals such as previous employers.

Why we process personal data
We process data with a view to entering into an employment contract with you, to ensure we are complying with legal obligations, and as part of our legitimate interests in running our business.

We will only rely on our legitimate interests as a reason for processing data where we have concluded that our interests are not overridden by the rights and freedoms of employees or workers.

Information on health conditions counts as a special category of personal data. We process this data to carry out our legal obligations as an employer and for the purposes of assessing the working capacity of the individual.

Processing data allows us to:

  • Communicate with you and internally
  • Manage recruitment and sub-contractor procurement processes
  • Maintain up-to-date records including records of contractual and statutory rights
  • Get occupational health advice and comply with duties in relation to people with medical conditions and disabilities
  • Meet legal obligations including compliance with employment, health and safety, and anti-discrimination laws
  • Respond to and defend against legal claims
  • Maintain and promote equality in the workplace

We do not make employment decisions based solely on automated decision-making.

Who we share personal data with
We share job applicant data with colleagues. We may share personal data with third parties to obtain references and perform pre-employment checks.

We also share personal data with our website/email service host, employment lawyers, HR advisors, and IT support providers.

We share data with third party cloud software providers acting as data processors in helping us operate our business. In providing services to us, these third parties may share personal data with other companies acting as sub-processors. Third party software suppliers we use in processing your data include (but are not limited to) providers of office administration and email software and HR management services.

We may also share your data with third parties in the context of a sale of some or all of the business.

External providers are subject to change. You can ask us for current details by speaking to Judith Clayman in HR, emailing info@axiongroup.co.uk or calling +44 161 426 7731

Otherwise, we only share data with other organisations as required by law.

How we protect personal data
Where we share information with colleagues, this is limited to the information necessary for the purposes of the business activity involved.

Where data is stored on our own servers, we apply high levels of security and store data in files to which only relevant and authorised staff have access. We store paper-based information in locked filing cabinets to which only relevant and authorised staff have access.

We provide appropriate data protection training for staff.

Where we share information with third party organisations acting as data processors for us either within the European Economic Area or outside it, the third parties are organisations committed to GDPR compliance and to high standards of data security. They act according to agreed instructions and are under a duty of confidentiality.

We are working towards the UK government’s Cyber Essentials accreditation to help us make sure we are doing everything possible to keep data safe.

Where we share personal data in other contexts, the sharing is subject to confidentiality agreements.

How long we keep personal data
We keep your CV, letters of application and notes from interviews indefinitely.

Your rights
You have a number of rights as a data subject. You can:

  • Obtain a copy of the data we hold on you
  • Require us to change data that is wrong
  • Require us to delete or stop processing data, for example, where we no longer need the data
  • Object to the processing of your data where we are relying on our legitimate interests as the legal basis for processing
  • Ask us to stop processing your data for a period of time if there is a dispute about whether or not your interests override our legitimate grounds for processing the data

To exercise any of these rights, email info@axiongroup.co.uk or call +44 161 426 7731 and ask for Judith Clayman.

 

  • Website use

We collect, store and use information about the device you are using and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths).

Cookies
We may use cookies on our website to help us understand how people use the site and to improve it. Cookies are files sent from the web server to the browser and back again. We use Google Analytics cookies to collect anonymous information such as how many visitors come to the site, how visitors have reached the site, and what pages they visit. Cookies do not generally contain any information that identifies a user, though there might be links between the personal information we hold on you and the information we get from cookies. You can disable cookies in your browser if you don’t want them to be used – see the browser help menu to find out how.