Privacy Policy – UNA

Welcome to the Arctic Shores Limited (“Arctic Shores”) privacy policy.

Arctic Shores respects your privacy and is committed to protecting your personal data. This privacy policy 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.

1. Important Information and Who We Are

 

Purpose of this privacy policy

This privacy policy aims to give you information on how Arctic Shores collects and processes your personal data through your use of our platform. whether you are an employee or candidate for employment who has been asked to take an assessment, a representative of one of our clients or anyone else who has been asked to take an assessment. For simplicity we will use the term ”candidate” to cover all these categories.

This website is not intended for anyone under the age of 16 and we do not knowingly collect data relating to individuals who are under that age.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Arctic Shores Limited is the controller and responsible for your personal data (collectively referred to as Arctic Shores, “we”, “us” or “our” in this privacy policy).

Where you are a candidate who has been invited to take an assessment by one of our clients, that client also determines some of the purposes for which your personal data will be processed and will also be a controller who is responsible for your personal data, in particular in relation to the initial provision of your contact details to us, and the use of the results provided to them. They will provide you with separate information about how they use this information.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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 policy of every website you visit.

2. The Data We Collect About You – CANDIDATES

 

Identity and Contact Data

When you are invited to take our behaviour-based assessment by us or one of our clients, the client will provide us with basic information about you including your [name, email address and details of the employer and role you are applying to]. This information may also be provided to us in a pseudonymised format where we will purely have a candidate ID that will identify you as a candidate. This information will be uploaded by our client to our platform. We use this on behalf of our client, and for our own legitimate interests in administering the service to our clients.

[We will not contact you directly using your contact details, will not send you any marketing, and none of our analysis relies on knowing your identity. Where we have your email address we will retain it as we may use your information to assess your fit for another role if you apply for another role for the original or another client who uses Arctic Shores services within the last 12 months period. You will be informed of this at the time and given the right to object, however it is standard industry best practice that psychometric assessments aren’t re-taken within a 12 months period.

Assessment Data

You will then be invited to carry out the assessment. We will collect data from your interaction with the assessment which analyses your responses against a number of success criteria . We may also collect additional information about you such as demographic data. We call this your “Assessment Data” and it consists of a number of data points. We then analyse the Assessment Data against the job fit criteria provided by our client who you are applying for employment with. This will focus on those criteria which are most important to the role which you are applying for. We will provide the results of this analysis (the “Assessment Result”, success criteria scores, aggregated and anonymised demographic data) to our client, but will not provide them with the underlying raw data or personal data associated with the assessment or demographic information.

We do not make decisions on behalf of our clients as to who will be employed, and provide them with the Assessment Data and Assessment Result which they can use to support them to make that decision.

As a research led organisation, we then remove identifiers from your Assessment Data and use the de-identified data for research and statistical analysis purposes – this includes development and enhancement of our services and products (for example creating generic job fit profiles for certain roles), as well as academic research. We may share the anonymised data with third party researchers, for example university researchers, for this purpose. We may also use it in order to write reports on benchmarking, industry statistics and market trends. You will not be identified in any outputs resulting from this analysis, and it will not be used to make decisions about you. We do this on the basis of our legitimate interests in product development and contributing to academic research in the field.

We may also ask you whether you would like to complete a survey. It is your choice whether to do this and we will only process your data in this way where we have received your consent. We will be data controller in respect of any Personal Data collected in this way.

Applying for employment with Arctic Shores

Where you apply for employment with Arctic Shores we will carry out the process described above, but will be the only organisation responsible for the use of your data. We also have further information on how we use personal data in the recruitment process which will be provided to you as part of that process.

Support

If you encounter difficulties using the assessment you may need to contact us for support. If you do this, we will collect identity and contact data about you in order to respond to that request and may also need technical information about your equipment or need to access details of your assessment session in order to resolve your issue. We do this for our legitimate interest in providing services to our clients.

We may also use information collected through this process to improve our products and services or fix bugs, but this will not usually involve personal data about you. We may also ask you to collect a candidate satisfaction survey in order to obtain your thoughts on our products and services.

Special Category Data

We may collect limited Special Categories of Personal Data about you relating to disability and / or ethnicity. We treat this Personal Data as Assessment Data. However we do not collect details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, other information about your health, or genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

Information about learning difficulties is used in order for us to make adjustments for candidates where necessary.

Information about ethnicity is used [for equal opportunities monitoring and in order for us to monitor demographics. While our clients may receive a summary report containing aggregated data for all their candidates they will not receive a candidate’s specific responses.

3. THE DATA WE COLLECT ABOUT YOU – CLIENTS

 

Account Administration

We will collect contact details and access credentials for authorised users including title, name, email address, telephone number and password for personnel of our clients who are involved in managing or administering the relationship. We will use these for contract management purposes, including accounts and financial administration and dealing with technical issues. We do this on the basis of our legitimate interest in providing services to our clients and providing them with access to our platform.

We may also use this data for marketing our products and services, or for providing service updates. We will give you the ability to opt out of marketing, although important service updates may be sent to all users, even those who do not wish to receive marketing.

Development of Job Fit Criteria

We may ask employees of our clients to carry out an assessment in order to determine appropriate job fit criteria for a role based on those people already carrying out the role. Where this applies, your data will be used as set out above in relation to candidate data. We do this on the basis of our legitimate interest in providing services to our clients.

Special Category Data

To support our validation studies, we may collect limited Special Categories of Personal Data about you relating to disability and / or ethnicity. We treat this Personal Data as Assessment Data. However we do not collect details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, other information about your health, or genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

OTHER INFORMATION

Automatically collected data

With regard to each Candidate who visits our behaviour-based assessment or a Client contact accessing UNA or the DataHub we may automatically collect the following information:

Technical information, including a device identifier, the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Services (including date and time), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

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. We only use cookies that are necessary for the provision of assessment.

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.

4. Disclosures of Your Personal Data

We may share your personal data with our clients as set out above. We may also share it with 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 policy.

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 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.

5. International Transfers

Some of our clients are based outside the UK. Because we only disclose your Assessment Result to those clients who you are applying to, you will be made aware of their identity and location at the relevant time.

Some of our third party service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

6. 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.

7. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We retain candidate contact details for the purpose of identifying repeat test requests for [12 months]. We retain our anonymised research datasets beyond the end of this period, but once we have deleted your identifying details you can no longer be identified, and the research data does not constitute personal data.

We will retain account management data for the duration of the contract with the relevant client.

In some circumstances we will 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.

8. Your Legal Rights

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. 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:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• 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.

If you wish to exercise any of the rights set out above, please contact us using the contact details set out above.

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 could 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 could 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.

Contact details

We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection manager using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our data protection manager in the following ways:

Arctic Shores Limited
Address; 17 Marble Street, Manchester, M2 3AW
Email address: info@arcticshores.com
Telephone number: 0844 848 0424

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.