Privacy Policy & Data Protection
1. Introduction
Wise Connection Partners Ltd ("the Company", "we", "us" or "our") is committed to protecting the privacy, confidentiality, integrity and security of personal information entrusted to it in the course of its business operations.
This Privacy Policy sets out the principles and procedures governing the collection, receipt, processing, handling, storage, disclosure and disposal of personal information in accordance with applicable United Kingdom data protection legislation, including the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and other applicable privacy legislation, as amended from time to time.
The Company primarily acts as a Data Processor in respect of personal information supplied by business clients and other organisations acting as Data Controllers.
Wise Connection Partners Ltd does not independently generate consumer leads and processes personal information supplied to it solely for the purposes authorised by, and in accordance with the documented instructions of, the relevant Data Controller.
The Company acknowledges its legal obligations as a Data Processor and is committed to ensuring that all personal information is handled lawfully, securely and in accordance with the applicable contractual and statutory requirements.
2. Company Information
Wise Connection Partners Ltd
Company Registration Number: 12750337
ICO Registration Number: ZA775675
Registered Office: Winton House, Winton Square, Basingstoke, RG21 8EN, United Kingdom
Email: info@wiseconnection.co.uk
Telephone: 01256 578082
Website: www.wiseconnection.co.uk
3. Our Role as a Data Processor
For the purposes of Article 4 of the UK GDPR, Wise Connection Partners Ltd acts as a Data Processor where it processes personal information on behalf of another organisation that determines the purposes and essential means of that processing.
The relevant Data Controller retains responsibility for determining the lawful basis upon which personal information is obtained and processed, establishing the purposes for which it may be used, and ensuring that individuals are provided with the privacy information required by applicable legislation.
In its capacity as a Data Processor, Wise Connection Partners Ltd shall:
- Process personal information only upon the documented instructions of the relevant Data Controller, unless otherwise required by applicable law.
- Ensure that personal information is not used for any independent, unauthorised or incompatible purpose.
- Implement appropriate technical and organisational measures to safeguard personal information.
- Ensure that authorised personnel are subject to appropriate confidentiality obligations.
- Assist the Data Controller in fulfilling its statutory obligations, where required.
- Comply with the requirements of Article 28 of the UK GDPR and any applicable Data Processing Agreement.
For the avoidance of doubt, the Company shall not independently determine new purposes for the processing of personal information supplied by a Data Controller.
4. Categories of Personal Information Processed
In providing services to its business clients, Wise Connection Partners Ltd may receive and process personal information including, but not limited to:
- Names and personal identification details.
- Residential and correspondence addresses.
- Email addresses and telephone numbers.
- Consumer enquiry and service-related information.
- Records of communications and correspondence.
- Information concerning marketing preferences and permissions, where applicable.
- Other information supplied by the relevant Data Controller and necessary for the performance of authorised services.
The precise categories of personal information processed will depend upon the nature of the services provided and the documented instructions of the relevant Data Controller.
The Company will not intentionally process special category personal data or criminal offence data unless such processing is specifically authorised, lawful and subject to the applicable additional safeguards.
5. Source of Personal Information
Wise Connection Partners Ltd receives personal information from business clients and other organisations authorised to provide such information for processing.
The Company does not independently generate consumer leads or determine the original purposes for which client-supplied personal information is collected.
Responsibility for establishing an appropriate lawful basis for the original collection and intended use of personal information rests with the relevant Data Controller.
Wise Connection Partners Ltd will take appropriate steps, proportionate to its role and the nature of the processing, to ensure that the processing instructions it receives are consistent with applicable data protection requirements.
Where the Company considers that an instruction infringes applicable data protection legislation, it will inform the relevant Data Controller in accordance with Article 28 of the UK GDPR, unless legally prohibited from doing so.
6. Purposes of Processing
Personal information supplied to Wise Connection Partners Ltd will only be processed for the purposes specified or authorised by the relevant Data Controller. Depending upon the contractual arrangements, such processing may include:
- Receiving and securely maintaining personal information.
- Managing and administering information on behalf of business clients.
- Undertaking authorised communications and administrative activities.
- Updating, organising and maintaining records.
- Facilitating authorised business operations and service delivery.
- Transferring or returning personal information in accordance with documented instructions.
- Carrying out other lawful processing activities expressly authorised by the relevant Data Controller.
The Company will not use client-supplied personal information for its own independent marketing, commercial exploitation or unrelated business purposes.
7. Data Processing Agreements
Where Wise Connection Partners Ltd acts as a Data Processor, processing activities shall be governed by a written agreement or other legally binding arrangement satisfying the requirements of Article 28 of the UK GDPR. Such arrangements shall identify, as applicable:
- The subject matter and duration of processing.
- The nature and purpose of processing.
- The categories of individuals concerned.
- The types of personal information processed.
- The obligations and rights of the Data Controller.
- The duties and responsibilities of Wise Connection Partners Ltd as Data Processor.
- Applicable confidentiality, security and retention requirements.
- Procedures for handling data subject requests and personal data breaches.
- Conditions governing the appointment of sub-processors.
- Requirements for the return or deletion of personal information upon termination of services.
- Applicable audit, inspection and compliance obligations.
The Company will comply with the terms of the relevant Data Processing Agreement, subject always to applicable statutory obligations.
8. Confidentiality and Data Security
Wise Connection Partners Ltd is committed to maintaining appropriate technical and organisational security measures designed to protect personal information against unauthorised access, accidental loss, unlawful disclosure, alteration, destruction or misuse.
Such measures shall be appropriate to the nature, scope, context and purposes of processing and the risks presented to individuals.
Access to personal information shall be restricted to authorised personnel who require such access for legitimate and approved business purposes.
All personnel authorised to process personal information shall be subject to appropriate confidentiality obligations, whether contractual or statutory.
The Company will take reasonable and proportionate steps to maintain the ongoing confidentiality, integrity, availability and resilience of its processing systems and services.
Security measures will be reviewed and updated where appropriate, taking account of technological developments, identified risks and applicable legal requirements.
9. Disclosure and Sub-Processing
Wise Connection Partners Ltd will not disclose personal information to unauthorised third parties.
Personal information may only be disclosed where such disclosure is authorised by the relevant Data Controller, necessary for the performance of agreed services, or otherwise required or permitted by applicable law.
The Company shall not appoint another Data Processor or sub-processor to undertake processing on behalf of a Data Controller without the prior specific or general written authorisation of that Data Controller.
Where an authorised sub-processor is engaged, appropriate contractual obligations shall be imposed to ensure that personal information receives a level of protection consistent with the requirements of Article 28 of the UK GDPR.
Wise Connection Partners Ltd shall remain responsible to the relevant Data Controller for the performance of its authorised sub-processors' applicable data protection obligations.
10. Personal Data Breaches
In the event of a suspected or confirmed personal data breach affecting information processed on behalf of a Data Controller, Wise Connection Partners Ltd shall take appropriate action to investigate, contain and mitigate the incident.
The Company shall notify the relevant Data Controller without undue delay after becoming aware of a personal data breach.
Such notification shall include available information reasonably necessary to assist the Data Controller in assessing the incident and fulfilling any applicable regulatory or individual notification obligations.
Wise Connection Partners Ltd shall cooperate with the relevant Data Controller in investigating the incident and implementing appropriate remedial measures.
Where the Company acts solely as a Data Processor, responsibility for notifying the Information Commissioner's Office and affected individuals will ordinarily rest with the relevant Data Controller, subject to any separate legal obligations applicable to the Company.
11. Data Retention and Disposal
Wise Connection Partners Ltd will retain personal information processed on behalf of a Data Controller only for the period authorised by that Data Controller or otherwise required by applicable law.
Retention arrangements shall be governed by the relevant contractual terms, documented processing instructions and applicable statutory requirements.
Upon termination or completion of the relevant processing services, the Company shall, at the choice of the Data Controller, securely return or delete the personal information concerned and delete existing copies, unless applicable law requires continued retention.
Where continued retention is legally required, the Company shall ensure that the information remains appropriately protected and is not processed for unauthorised purposes.
12. Rights of Individuals
Individuals have certain rights under applicable data protection legislation, including rights relating to access, rectification, erasure, restriction of processing, data portability, objection and qualifying automated decision-making.
Where Wise Connection Partners Ltd receives a request concerning personal information processed solely on behalf of a Data Controller, the Company will refer the request to the relevant Data Controller or otherwise handle it in accordance with the Controller's documented instructions and applicable legal requirements.
The Company will provide reasonable assistance to the Data Controller in responding to such requests, taking account of the nature of the processing and the information available to it.
Wise Connection Partners Ltd shall not independently determine the outcome of a data subject rights request concerning client-controlled personal information, except where required or authorised by applicable law.
13. International Data Transfers
Wise Connection Partners Ltd shall not transfer personal information outside the United Kingdom except in accordance with the documented instructions of the relevant Data Controller and applicable data protection legislation.
Where a restricted international transfer is authorised, the Company shall ensure that appropriate transfer mechanisms and safeguards are implemented where required.
Such safeguards may include an applicable adequacy regulation, an approved International Data Transfer Agreement, or another legally recognised transfer mechanism.
14. Record Keeping and Accountability
Wise Connection Partners Ltd will maintain appropriate records of its processing activities where required under Article 30 of the UK GDPR.
The Company shall make available to the relevant Data Controller information reasonably necessary to demonstrate compliance with applicable Article 28 obligations.
The Company shall allow for and contribute to audits and inspections conducted by the Data Controller or an auditor mandated by the Data Controller, in accordance with applicable legal and contractual requirements.
15. Processing of the Company's Own Business Information
Notwithstanding its role as a Data Processor in respect of client-supplied personal information, Wise Connection Partners Ltd may act as an independent Data Controller in relation to personal information processed for its own legitimate business administration purposes.
Such information may include personal data relating to employees, job applicants, suppliers, professional advisers and business contacts.
Where acting as a Data Controller, the Company will determine and document the appropriate lawful basis for processing, provide relevant privacy information, establish appropriate retention arrangements and comply with the applicable obligations of the UK GDPR.
Where necessary, separate employee, recruitment or business contact privacy notices will be provided.
16. Data Protection Complaints
Individuals who have concerns regarding the processing of their personal information may contact Wise Connection Partners Ltd using the details provided in this Policy.
Where a complaint relates to information processed solely on behalf of another Data Controller, the Company may refer the matter to that organisation and will provide reasonable assistance as required.
Individuals also have the right to raise concerns with the Information Commissioner's Office.
Information Commissioner's Office — Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. Website: www.ico.org.uk
Nothing in this Policy shall operate to restrict or exclude any statutory right available to an individual under applicable data protection legislation.
17. Review and Amendment
Wise Connection Partners Ltd reserves the right to review, amend or update this Privacy Policy where necessary to reflect changes in legislation, regulatory guidance, contractual requirements or business operations.
Any material amendments will be communicated where required by applicable law.
The Company will periodically review this Policy to ensure that it remains appropriate to its processing activities and legal obligations.
18. Contact Details
For enquiries relating to this Privacy Policy or the Company's handling of personal information, please contact:
Wise Connection Partners Ltd, Winton House, Winton Square, Basingstoke, RG21 8EN, United Kingdom
Email: info@wiseconnection.co.uk
Telephone: 01256 578082
ICO Registration Number: ZA775675