This Notice explains how we may Process your Personal Data. Please read this notice carefully to understand our practices regarding your Personal Data and how we will handle it.
You have a legal right to object at any time to: (i) use of your Personal Data for direct marketing purposes; and (ii) processing of your Personal Data which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
This Notice is issued by Online Trading Limited with the trading name of “New Horizons” (together “New Horizons”, “we”, “us” and “our”) and is addressed to anyone in the European Union who is using, or has access to New Horizons services or website (together, “you”, “your”).
Online Trading is a limited company registered in England under company number 3008741. Our registered office is Chancery House, 199 Silbury Boulevard, Central Milton Keynes MK9 1JL and our trading address is Summit House, 12 Red Lion Square, London WC1R 4HQ. Our VAT number is 653 3100 74.
For the purposes of the Data Protection Legislation and this Notice we are the “data controller”.
Purpose of This Notice
This Notice describes how we collect and use personal information about you (your “Personal Data”), in accordance with the General Data Protection Regulation (GDPR) and any other data protection and privacy laws and regulations applicable to us or to our processing of your Personal Data (‘Data Protection Legislation’).
New Horizons Data Subjects
For the purposes of this Notice our Data Subjects comprise:
- Our “Clients”: this term covers Corporate Clients (the corporate entity or sponsor that engages our services; HR Personnel (who represent the corporate entity); the employees of corporate clients; and other people who use our services;
- Our “Employees”: this term covers our Directors, employees, consultants, workers and job applicants;
- Our “Associate Consultants”: this term covers our regionally based associate consultants, coaches and CV writers who provide our services to our clients on our behalf and act as our Data Processors;
- Our suppliers and service providers and their agents, employees and representatives; and
- Visitors to our website.
Collection of Personal Data
If you are a Client then we may collect and process information about you (i) when you request a proposal from us in relation to the provision of our services (ii) when you, your employer or sponsor engages us to provide our services; (iii) during the course of the provision of those services; (iv) through the management and administration of the service; and (v) to maintain our business relationship and provide further services to you.
If you are an Employee then we will collect and process additional personal information about you as described in your employment contract, our employee policies, and/or any other applicable separate documents provided to you in connection with your position or your application for a position with us.
If you are an Associate Consultant then we may collect and process information about you as described in your Consultant Agreement, our associate consultant policies and/or any other applicable separate documents provided to you in connection with the work you undertake for us.
All Data Subjects
We may collect and process Personal Data about you from the following sources:
Data you provided: We may obtain your Personal Data when you provide it to us (e.g. where you contact us via email, telephone, post or social media)
CV and Application Data: We will obtain your Personal Data when you provide us with your CV or any other application data that you use to apply for jobs
Relationship Data: We will likely obtain further Personal Data about you during the course of our relationship with you
Data you make public: We may collect or obtain your Personal Data that you choose to make public, including via social media (e.g. we may collect information from your social media profile(s), if you make a public post about us)
Site data: We may collect or obtain your Personal Data (i) when you visit our website; (ii) when you submit your contact details and other information about yourself or your organisation through forms on our website; and (iii) when you use any features or resources available on or through our website.
Third party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g. referees; etc).
The type of Personal Data we may Process
The information we hold about you may include the following:
- Your name, address, email and any other contact details
- Relevant information from your CV, such as your job history
- Your educational history, qualifications and skills
- Family and other personal information such as hobbies, interests and pastimes
- Information about any enquiries you may have submitted to us
- Details of any contacts we have had with you in relation to the provision, or the proposed provision, of our services
- Details of any services you have received from us
- Our communications and correspondence (email and post) with you
- Information provided by your employer, sponsor or other relevant organisation
- Information we receive from other sources, such as publicly available information
- Your purchase and payment details (e.g. your billing address)
- We may also create Personal Data about you (e.g. records of your interactions with us)
Lawful basis for Processing Personal Data
In processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:
Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory);
Contractual: We may Process your Personal Data for purposes necessary for the performance of our contract with you, or for steps preparatory to entering into a contract with you;
Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law;
Vital interests: We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual; or
Legitimate interest: We may Process your Personal Data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of your Personal Data. This includes Processing for marketing, business development, statistical and management purposes.
Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data. However, to the extent that you do provide us with any Sensitive Personal Data, such as data that you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our services. Where we need to Process your Sensitive Personal Data it will be for one of the following reasons:
- You have explicitly consented to the Processing
- For the purposes of our assessment of your suitability for job roles or working capacity
- Where Processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
- To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
Purposes for which we may Process your Personal Data
We may process your Personal Data for the following purposes, subject to applicable law:
Provision of our services to you: Providing our outplacement, career transition, coaching and career management services to you, including our online career management software i-Horizons, or any other related services that you have requested and communicating with you in relation to those services.
Tailoring our services: Personalising our services to your requests and preferences
Management and administration of our services: Operating and managing our services and i-Horizons; providing content to you; displaying information to you; communicating and interacting with you and notifying you of changes to i-Horizons or our other services.
Communications: Communicating with you via any means (including via email, telephone, text message, social media, post or in person) information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
Communications and IT operations: Management of our communications systems; operation of IT security systems; and IT security audits.
Feedback and surveys: Engaging with you for the purposes of obtaining your views on our services.
Improving our services: Identifying any issues with our services or i-Horizons and planning improvements or creating new services.
Investigations: Detecting, investigating and preventing breaches of policy, and criminal offences in according with applicable law.
Legal proceedings: Establishing, exercising and defending legal rights.
Legal compliance: Compliance with our legal and regulatory obligations under applicable law
Disclosure of Personal Data
We may disclose your Personal Data within New Horizons, for legitimate business purposes, including providing our services to you. In addition we may also disclose your Personal Data to the following “Third Parties” where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so:
- Our Associate Consultants who work with us as our Data Processors to provide you with the services you have requested
- Service Providers who process data on our behalf, which may include: IT support; i-Horizons systems provider; and data storage services including cloud providers
- Accountants, auditors, lawyers and other outside professional advisors to New Horizons, subject to binding contractual obligations of confidentiality
All of our Third-Party service providers are required to take commercially reasonable and appropriate security measures to protect your personal information. We only permit our Third-Party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may also disclose your Personal Data where we are required by law to:
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights
- Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security
- Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation)
Transferring Information outside The European Economic Area (EEA)
We will not ordinarily in the course of our business transactions transfer the Personal Data we collect about you outside of the EEA. However, where there is a need for your Personal Data to be processed by any third party based outside the EEA, which will involve a transfer of data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your Personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
- We will ensure that the third party obtains your consent
Please contact us if you want further information regarding the transfer of your Personal Data outside of the EEA
We have put in place appropriate technical and organisational security measures designed to protect your Personal Data against accidental loss, alteration, unauthorised access, use or disclosure. In addition we limit access to your Personal Data to those employees, associate consultants and other third party agents and contractors 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.
However, because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you sent to us is sent securely.
We will notify you and any applicable regulator of any suspected data security breach where we are legally required to do so.
Your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice. It is important that the Personal Data we hold about you is accurate and current. We take every reasonable step to ensure that:
- Your Personal Data that we Process is accurate and, where necessary, kept up to date
- Any of your Personal Data that we Process that is inaccurate is erased or rectified without delay
Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Retaining your Personal Data
The length of time we will hold and store your Personal Data will depend on the services we perform for you and for how long you require those. As we often support clients over many years, and potentially throughout their careers, the purpose for which we retain data is often an ongoing purpose.
We will hold and store your Personal Data for the duration of your employment with us and for a period of a further 3 years after you have left our employment.
We will store and hold your Personal Data for the duration of the time you work for us and for a period of a further 3 years after you stop working for us.
All Data Subjects
In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your Personal Data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, or we are subject to a legal obligation which applies for a longer period.
Please contact us if you would like further information regarding retention of your Personal Data.
If however, you believe that we should delete your Personal Data at an earlier date, please inform us in writing and also of your reasons. Please see ‘Your Legal Rights’ below.
Your Legal Rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:
- The right not to provide your Personal Data to us (however please note that if you withhold your Personal Data we may not be able to provide you with the full benefit of our services)
- The right to request access to, or copies of, your Personal Data, together with information regarding the nature, Processing and disclosure of your Relevant Personal Data
- The right to request rectification of any inaccuracies in your Relevant Personal Data
- The right to request, on legitimate grounds, erasure of your Relevant Personal Data
- The right to request, on legitimate grounds, restriction of Processing of your Relevant Personal Data
- The right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf
- The right to request the transfer of your Personal Data to another party
If you wish to exercise any of the above rights, please email: email@example.com.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights) as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
In those circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email: firstname.lastname@example.org.
Once we have 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.
Cookies are small text files that are placed on your machine automatically by a website, which help to ensure the website operates properly and your experience on that website is optimised. Cookies can be removed or blocked by yourself if you wish. We may use the following cookies:
Google Analytics: This allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. The information is depersonalised meaning that it cannot be tracked back to individuals. This will help to protect your privacy.
Google AdWords: Using Google AdWords code we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget.
Website cookies: These are used to enable the website’s functionality, improve the user experience or help us to optimise our website, measure traffic and other internal management purposes.
For further information about Cookies, and for guidance on removing them from your machine, please visit the All About Cookies website which provides information about Cookies and their removal on all modern browsers.
Changes to this Notice
Any changes we may make to our Privacy Notice in the future will be notified by publishing an updated version on our website at: www.newhorizonscareers.co.uk.
If you have any questions regarding this notice or if you would like to speak to us about the way in which we process your Personal Data, please email: email@example.com or telephone +44 (0) 20 7831 9843.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO: www.ico.org.uk), the UK supervisory authority for data protection issues, at any time. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.