ITOS Solutions Limited
ITOS Solutions Limited will collect and process the Personal Data of natural persons who are directors, officers, employees, agents and / or authorised signatories of ITOS Solutions Limited customers, suppliers, service providers, vendors and other commercial partners (“Individuals”) for the purposes of and in connection with ITOS Solutions Limited dealings with those commercial entities.
This Privacy Statement explains how ITOS Solutions Limited will manage the Personal Data of Individuals, why ITOS Solutions Limited uses it, and how Individuals may contact ITOS Solutions Limited in relation to the use of Personal Data. Personal Data (as per the GDPR definition) means any information which ITOS Solutions Limited has or obtains, or processes, or which an Individual provides to ITOS Solutions Limited, and specifically his / her name, address, email address, phone number(s), title or position, from which that Individual can be directly or indirectly personally identified.
Use of Personal Data and Basis of Processing
ITOS Solutions Limited will use the Personal Data where necessary:
where use is for a legitimate purpose of ITOS Solutions Limited, including: (a) for the purposes of managing its contracts and relationships with its customers, suppliers, service providers, vendors and other commercial partners; (b) for day to day operational and business purposes; (c) to take advice from ITOS Solutions Limited’s external legal and other advisors;
for compliance with ITOS Solutions Limited’s legal obligations, including: (a) compliance with applicable tax and regulatory reporting obligations; (b) where ITOS Solutions Limited is ordered to disclose information by a court with appropriate jurisdiction;
where necessary to establish, exercise or defend its legal rights or for the purpose of legal proceedings;
where an Individual has consented to use for a particular purpose. If an Individual gives consent for ITOS Solutions Limited to use his / her Personal Data for a particular purpose, that Individual has the right at any time to withdraw consent to the future use of his / her Personal Data for some or all of those purposes by writing to the address specified below.
board reporting and management purposes, including quality assurance;
in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation or disposal of ITOS Solutions Limited;
Applicants for Jobs
Where you, or a third party recruitment agent acting for you, provide us with your CV and other Personal Data, we will use that information solely for the purposes of considering your application for a position with ITOS Solutions Limited, including checking your references. However, we will only hold Personal Data of applicants for positions for a period of 12 months from our final interaction with a candidate during the recruitment process. If you are a successful candidate, some of the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate Employee privacy statement.
Sharing Personal Data
ITOS Solutions Limited will not disclose any Personal Data to any third party, except as outlined above and / or as follows:
- to enable ITOS Solutions Limited to carry out the obligations under and enforce its contracts with its customers, suppliers, service providers, vendors and other commercial partners;
- where ITOS Solutions Limited needs to share Personal Data with its auditors, and legal and other advisors;
- in the event of a merger or proposed merger, any (or any proposed) transferee of, or successor in title to, the whole or any part of ITOS Solutions Limited’s business, and their respective officers, employees, agents and advisers, to the extent necessary to give effect to such merger;
- the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of ITOS Solutions Limited’s regulators.
Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with the uses described above, where an Individual has explicitly consented, and / or as otherwise required or permitted by law. Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in the European Union.
Third Party Providers of Information
ITOS Solutions Limited may obtain Personal Data relating to Individuals from someone other than that Individual, such as his / her employer. The person providing the information will be asked to warrant that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that ITOS Solutions Limited will hold information relating to them and that it may use it for any of the purposes set out in this privacy statement, and where necessary that it will obtain consent to ITOS Solutions Limited’s use of the information.
Recipients of the Personal Data
In any case where ITOS Solutions Limited shares Personal Data with a third party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Updates to Personal Data
ITOS Solutions Limited will use reasonable efforts to keep Personal Data up to date. However, each Individual will need to notify ITOS Solutions Limited without delay in the event of any change in his / her personal circumstances, or those of the others mentioned above, so that ITOS Solutions Limited can keep the Personal Data up to date.
Retention of Personal Data
ITOS Solutions Limited is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal and regulatory purposes, and for legitimate business purposes. Information will be retained for no longer than is necessary for the purpose for which it was obtained by ITOS Solutions Limited or as required or permitted for legal and regulatory purposes, and for legitimate business purposes. In general, ITOS Solutions Limited will hold this information for a period of seven years after an Individual ceases to interact with ITOS Solutions Limited, unless it is obliged to hold it for a longer period under law or applicable regulations.
An Individual’s Rights in relation to Personal Data
An Individual may at any time request a copy of his / her Personal Data from ITOS Solutions Limited. This right can be exercised by writing to ITOS Solutions Limited at the address specified below.
An Individual also has the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of his / her Personal Data, and to object to certain uses of his / her Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with ITOS Solutions Limited’s processing of Personal Data can be obtained by writing to ITOS Solutions Limited at the address specified below.
In any case where ITOS Solutions Limited is relying on an Individual’s consent to process his / her Personal Data, that Individual has the right to change his / her mind and withdraw consent by writing to the address specified below.
Where ITOS Solutions Limited is relying on a legitimate purpose of ITOS Solutions Limited or a third party recipient of the Personal Data, in order to use and disclose Personal Data, an Individual is entitled to object to such use or disclosure of his / her Personal Data, and if he /she does so, ITOS Solutions Limited will cease to use and process the Personal Data for that purpose unless ITOS Solutions Limited can show there are compelling legitimate reasons for it to continue or it needs to use the Personal Data for the purposes of legal claims.
An Individual also has the right to lodge a complaint about the processing of his / her Personal Data by ITOS Solutions Limited with the Data Protection Commission at firstname.lastname@example.org.
Contacting ITOS Solutions Limited
Any queries or complaints regarding the use of the Personal Data by ITOS Solutions Limited and / or the exercise of individual rights should be addressed to ITOS Solutions Limited at email@example.com
Updated May 25th 2018 – version 1/052018