Aston Business Assessments Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
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Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Aston Business Assessments Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account, complete a test or assessment via our website, sign up to our newsletter or mailing list or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Aston Business Assessment Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (see paragraph 9), please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Aston Business Assessment Limited
Name of data privacy manager: Stephen Woods
Email address: dataprotection@astonassessments.co.uk
Postal address: Aston Business Assessments, Vincent Court, Hubert Street, Aston Lock, Birmingham, B6 4BA
Telephone number: 0121 270 5592
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 23/05/2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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The data we collect about you
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 (such as anonymous data).
We have set out below the different kinds of personal data (in relevant groups) which we may collect about you. The kinds of personal data which we collect about you will depend on how you interact with us. We have identified 4 main ways in which you may interact with us:
- the organisation which you represent is one of our clients and purchases services from us and you register as a user on behalf of your organisation in order to access and to use the services (referred to in this privacy notice, where relevant, as a “Client User”);
- you are referred to us by an organisation as a candidate to take a test or assessment via our website (referred to in this privacy notice, where relevant, as a “Respondent User”);
- you or the organisation which you represent are one of our resellers (and have entered into a reseller agreement with us) and you register as a reseller user in order to access relevant services (referred to in this privacy notice, where relevant, as a “Reseller User”);
- you are a visitor to our website (referred to in this privacy notice, where relevant, as a “Visitor”).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, title, age, gender, nationality, job title, employer and identifiers such as an employee number or any national identity card number.
- Contact Data includes address(es), email address(es) and telephone number(s).
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about transactions you have entered into via the website.
- Respondent Data includes answers which you provide to assessments and tests which you complete via the website, results and reports which are produced from your completion of an assessment or test via the website and responses provided by any nominees about the respondent via the website.
- Technical Data includes the internet protocol (IP) address you use to access this website.
- Profile Data includes your email address (which is used as a username) and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that the exact groups and types of personal data which we collect and use about you will depend upon whether you are a Client User, Respondent User, ReSeller User or Visitor. If you require confirmation about exactly which groups or types of data we will collect about you depending on who you are, please contact us using the details set out above.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We may also anonymise and aggregate the Respondent Data to assist with generating and updating our norm groups to allow us to improve our norm groups and to ensure that they are accurate. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of personal data (sensitive data)
There are certain types of personal data which require higher protection under data protection legislation. These are known as “Special Categories of personal data” and they include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect these from you. If for any reason we do decide to collect, use and store any Special Category of personal data we will get your explicit written consent to do so and will provide you with full details of the Special Category of personal data that we would like to collect and the reason we need it, so that you can carefully consider whether you wish to consent.
We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with your organisation (where you are a client of ours) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service your organisation has with us but we will notify you if this is the case at the time. If you are a Respondent User and do not provide us with the personal data requested then we may not be able to fulfil the contract with the organisation which introduced you to us and we will inform them if this cannot be completed.
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How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us some feedback.
If you are a Respondent User, you may give us your Identity, Contact and Respondent Data by creating an account on our website and by completing an assessment or test via our website.
If you are a Client User, you may give us your Identity and Contact Data by creating a client user account on our website.
If you are a Reseller User, you may give us your Identity and Contact Data by creating a client user account on our website.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
Technical Data from analytics providers such as Google based outside of the EU.
Contact, Financial and Transaction Data from providers of technical and payment services such as Stripe Inc (who we use for most payment services) which are based outside the EU.
If you are a Respondent User the organisation which has requested you to complete a test or assessment via our website may pass your Identity and Contact Data to us.
If you are a Respondent User a nominee at the organisation which has introduced you to us may provide us with responses which constitute your personal data via the assessment or test on the website.
If you are a Client User, the organisation which uses our services or our resellers may provide us with your Identity and Contact Data.
If you are a Reseller User, the organisation which is the reseller may provide us with your Identity and Contact Data.
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How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data on the basis of one of the following lawful reasons:
- “Legitimate Interests Reason” – this is where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to provide our services and a secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- “Legal Obligation Reason” – this is where we need to comply with a legal or regulatory obligation.
- “Consent Reason” – this is where you provide your consent to us collecting, using and storing your personal data. You have the right to withdraw your consent at any time (which is explained further in paragraph 10 below).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new Respondent User |
(a) Identity Data
(b) Contact Data
(c) Profile Data |
Legitimate Interests Reason - because our client (the third party) has requested you to complete an assessment via our website and we are fulfilling our contract with our client (and the fulfilment of that contract is in our legitimate interests). |
To register you or the organisation you are acting on behalf of as a new Client User. |
(a) Identity Data
(b) Contact Data
(c) Profile Data |
Legitimate Interests Reason - because our client (the third party) wishes to use and access the services offered on our website and we are fulfilling our contract with our client (and the fulfilment of that contract is in our legitimate interests). |
To register you or the organisation you are acting on behalf of as a new Reseller User. |
(a) Identity Data
(b) Contact Data
(c) Profile Data |
Legitimate Interests Reason - because the reseller (the third party) wishes to use and access the services offered on our website and we are fulfilling our contract with the reseller (and the fulfilment of that contract is in our legitimate interests). |
To process and deliver the order for services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us. |
(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data |
Legitimate Interests Reason - to fulfil a contract with our client and to recover debts due to us. |
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or allowing you to provide feedback. |
(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data |
Necessary to comply with a legal obligation
Legitimate Interests Reason - to keep our records updated and to study how clients use our services |
To request and use responses to assessments and tests and to produce reports based on assessments or tests completed by Respondent Users and to provide these to our client. |
(a) Identity Data
(b) Contact Data
(c) Respondent Data
(d) Transaction Data |
Consent Reason.
Legitimate Interests Reason - because our client (the third party) wishes to use and access the services offered on our website and we are fulfilling our contract with our client (and the fulfilment of that contract is in our legitimate interests). |
To use data analytics to feed into and improve the psychometric norm groups which form part of the services which we offer to clients (however, this will be anonymised and aggregated data) |
(a) Respondent Data |
Legitimate Interests Reason - because in order to be able to provide services and to provide our client’s with accurate reports, we need to analyse and update psychometric norm groups. |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data |
Legitimate Interests Reason - for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
Necessary to comply with a legal obligation. |
To use data analytics to improve our website, services, marketing, customer relationships and experiences |
(a) Technical Data
(b) Usage Data |
Legitimate Interests Reason - to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy |
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Transaction Data
(b) Usage Data |
Legitimate Interests Reason - to grow our business. |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you or the organisation which you are representing (we call this marketing).
You will receive marketing communications from us if you (or the organisation which you are representing) have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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Automated decision making
Automated decision making is where a decision is automatically made without any human involvement. Under data protection laws this includes profiling. Profiling is the automated processing of personal data in order to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).
Data protection laws place restrictions upon us if we carry out solely automated decision making (including profiling) which produces a legal effect or similarly significant effect on you.
If you are a Respondent User completing an assessment or test via our website, then the assessment or test will be done by automated means and reports will be produced automatically. However, those reports will be provided to the organisation which introduced you to us and a human will review those reports and take decisions based on those reports and other information available to them. We therefore do not consider that the assessments or tests available on our website result in solely automated decision making.
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Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- If you are a Respondent User, we may share your personal data with the organisation which introduced you to us (and which is our client) and they will be acting as a data controller in relation to your personal data;
- If you are a Client User, we may share your personal data with any relevant reseller who introduced you to us and they will be acting as a data controller in relation to your personal data;
- External Third Parties including:
- Service providers such as IT providers, payment service providers and email platforms (such as Mailchimp) (who usually act as data processors) and who may be based either inside or outside of the EU;
- Our professional advisers such as lawyers, accountants, bankers, auditors, insurers, (who act as either data controllers or data processors, depending on the circumstances) who are usually based in the UK;
- HMRC and other authorities (who act as either data controllers or data processors, depending on the circumstances) who are usually based in the UK;
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers who are data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring 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.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, 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 confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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Data retention
How long will you use my personal data for?
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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax and accounting purposes.
If you are a Reseller User or a Client User we will keep Profile Data for 12 months following you ceasing to be a reseller or client (as relevant) (except where we are required to keep this for longer in relation to resellers in line with our contractual requirements to resellers, in which case this Profile Data will be kept for 12 months following fulfilment of the contractual obligations).
If you are a Respondent User we will keep Profile Data and Respondent Data for 37 months from the date you complete a test or assessment.
We will keep Technical Data and Usage Data for 12 months from the date of collection.
We will keep Marketing and Communications Data (which includes Identity and Contact Data) for the time when the individual is subscribed to our mailing list and for 6 months following the date of the individual unsubscribing from our mailing list.
In some circumstances you can ask us to delete your data: see the information about requesting erasure in paragraph 10 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
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Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are set out below. If you wish to exercise any of these rights, please contact us. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as 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 (including to objecting to profiling for direct marketing purposes). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.