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Legal Policies

PRIVACY NOTICE

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SECTION 1: Purpose


This Privacy Notice describes how we collect and use Personal Data about visitors to our website, clients and potential clients, third party consultants and any other individuals whom we may collect Personal Data on in accordance with the Data Protection Laws (which term includes the General Data Protection Regulations (EU 2016/679), Data Protection Act 2018, the UK GDPR (as defined in the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations (2019/419) and the Privacy and Electronic Communications (EC Directive) Regulations 2003). Past, present and prospective employees, workers, and contractors should refer to our Privacy Notice for Employees and our Pre-Hire Privacy Notice (found on our intranet and our recruitment webpage).
A-B-D-S 02 LTD is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Data. We are required under the Data Protection Laws to notify you of the information contained in this Privacy Notice. We may update this Notice at any time.

 

SECTION 2: Data Protection Principles


We comply with the Data Protection Laws. This says that the Personal Data we hold must be:

  • Used lawfully, fairly and in a transparent way.

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  • Relevant to the purposes we have told you about and limited only to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for the purposes we have told you about.

  • Kept securely.

 

SECTION 3: The kind of information we hold about you


Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, country of residence, company, and job title.

  • Contact Data includes address, email address and telephone numbers.

  • Professional Data includes CVs, and documents related to your qualifications, experience, and role, current salary, eligibility to work in the UK.

  • Usage Data includes information about how you use our website.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In limited circumstances, we may also collect, store and use documents to prove your identification such as a copy of your passport or address, and/or the following “special categories” of more sensitive Personal Data:

  • Information about your race or ethnicity, and religious beliefs.

  • Information about your health, including any medical condition.

  • Information about criminal convictions and offences.

The Personal Data we may collect varies depending upon how it is collected and for what purpose. More specific details are set out below.

 

SECTION 4: How is your Personal Data collected?


Personal Data may be collected in the following ways:

Through information collected by cookies when you use our website.
When you visit www.abds.com we may send a ‘cookie’ to your computer. This is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant pages. For details of the cookies employed by us see Section 11 below.
or:
Through information automatically recorded when you use our IT systems, so that the systems can run effectively and we can ensure they are not being misused.

Direct interactions – where you provide information by filling in forms or corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

  • Complete an online form to subscribe to our mailing list;

  • Make business enquiries via email or telephone; and

  • Enter into a working relationship with us.

or:

Third parties or publicly available sources. For example, consultants working with us whose CVs might be sent by their employer for bid documents or so we can assess their suitability for a project.

 

SECTION 5: How we will use information about you


We will only use your Personal Data when the law allows us to, such as:

  1. Where it is necessary to perform a contract with you or in order to take steps at your request prior to entering into a contract.

  2. Where we need to for compliance with a legal obligation.

  3. Where it is necessary for the purposes of our legitimate business interests to run a successful international design studio, and your interests and fundamental rights do not override those interests.

We may also use your Personal Data in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).

  2. Where it is needed in the public interest.

 

SECTION 6: Special Category Personal Data

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Special Categories of sensitive Personal Data require higher levels of protection and we will need to have further justification for collecting, storing and using this type of Personal Data, such as:

  1. In limited circumstances, with your explicit written consent.

  2. Where it is necessary for us to meet legal obligations.

  3. Where it is necessary for reasons of public interest.

  4. Where it is needed on health grounds, subject to appropriate confidentiality safeguards. 

  5. Where it is needed for legal claims.

  6. Where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

It is unlikely that we will need to collect or process Special Categories of sensitive Personal Data. Where we do need to, we will notify you and (where required) obtain your consent to the processing.

 

SECTION 7: More specific details of how we may use your Personal Data

We have set out in the table below details of the type of data we may collect (by reference to the groups described in Section 3 above), the ways we may 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.

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​​SECTION 8: 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.

Occasionally we may use Personal Data to send you updates about our business or invites to events. If you prefer not to receive promotional material from A-B-D-S 02 LTD, email us at INFO@A-B-D-S.COM and put “unsubscribe” in the subject line together with the name of the publication you wish to unsubscribe from.

Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.

 

SECTION 9: Data Sharing


We may share your Personal Data with third parties, including third-party service providers and other entities in the A-B-D-S 02 LTD Group where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest for the purpose of running a successful international design practice in doing so.

For example, we may share your Personal Data with:

  • professional advisors such as lawyers and accountants;

  • processors such as providers of cloud hosting solutions or translation companies;

  • an auditor, regulator, or to otherwise comply with the law.

We may share Personal Data, such as CVs of collaborating design consultants, to clients, potential clients or collaborating designers where this was the purpose of collection.

As we are an international design practice, we may share your Personal Data with other entities in our group. In particular, we share your Personal Data for the following purposes:

  • Where required to facilitate your travel to meetings in one of our international offices or in respect of a project abroad;

  • Where we are inviting you to an event held in one of our offices abroad.

9.1 How secure is your information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data in line with our policies and the law. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

9.2 Transferring information outside the UK

We are an international design practice and as such may transfer the Personal Data we collect about you to countries outside the UK. Where we do so, we will ensure that those transfers take place in accordance with the Data Protection Laws, including by entering into data transfer agreements (containing standard contractual clauses recognised or issued in accordance with the UK Data Protection regime, a copy of which can be obtained from the DPM) with recipients or obtaining your explicit consent. If you require further information about these protective measures, you can request it from the Data Protection Manager via the contact details set out below.

 

SECTION 10: Security

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All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way. 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.

 

SECTION 11: Accuracy

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We want to make sure that your Personal Data is accurate and up to date. Please contact us if any information we are using is not accurate or up to date.

 

SECTION 12: Retention

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We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it or 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.

In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

 

SECTION 13: Your Rights in Connection with Personal Data

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Under certain circumstances, by law 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 information we hold about you corrected.

  • 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 the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your Personal Data to another party.

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact the Data Protection Manager in writing.

13.1 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

13.2 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

13.3 Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Manager or use any unsubscribe link in any email newsletter that you receive. 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.

 

SECTION 14: Contact information

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Requests for further information about this Privacy Notice or about how we process Personal Data can be sent by email to: INFO@A-B-D-S.COM

 

Or in writing to:

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Data Protection Manager

A-B-D-S 02 LTD

Block R11

Sutherland St

London SW1V 4AX

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To deliver relevant website content to you and to use data analytics to improve our website.

 

To send marketing newsletters to you.

 

To invite you to events



 

To manage access to our premises and for security purposes.

To administer and protect this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

To respond to your new business enquiry as a potential client.
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To administer our working relationship with you and your employer (as applicable), such as providing and administering architectural and engineering services to you, and/or collaborating with you to bid for a design project or to provide design services.



 

 To carry out due diligence checks.








 

(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical

(a) Identity
(b) Contact
(c) Marketing and Communications

(a) Identity
(b) Contact
(c)Marketing and Communications

 

(a) Identify
(b) Contact
(c) Health

(a) Identity
(b) Contact
(c) Technical



 

(a) Identity
(b) Contact

 

(a) Identity
(b) Contact
(c) Professional Data

In limited circumstances we might require documents to prove your identification such as a copy
of your passport or Special Categories of sensitive Personal Data. In these circumstances we will notify you and where necessary obtain your consent.

​(a) Identify
(b) Professional Data









 

Lawful basis for processing including basis of legitimate interest.


 

​Necessary for our legitimate interests (to develop our business)
 

(a) Necessary for our legitimate interests for business development - to strengthen business relations and to market our services

(b) Necessary for our legitimate interests for running our business

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, and network security).
 

(a) Necessary for our legitimate interests (for winning and providing design services)

(a) Performance of a contract with you
(b) Necessary for our legitimate interests for winning and administering projects and running our business).







 

 (b) Necessary for our legitimate interests for running our business (to fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims, complying with our legal obligations, preventing crime or fraud and protecting the rights of third parties


Purpose/Activity
 


Type of data
 

Lawful basis for processing including basis of legitimate interest

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