Our Privacy Policy
Anglesey Associates Ltd is a professional consultancy, which specialises in market research, defence acquisition forecasting, management of complex defence procurement services, and operational support.
The Managing Director – who is Data Protection Lead - requires all employees to apply information security in accordance with the established policies and procedures of the organization.
We use Data Protection Impact Assessments to identify and analyse information risks. Each year, we set and review information security objectives and are able to demonstrate our commitment in our company culture and processes.
All applicable legal, statutory and contractual requirements regarding information security will be fulfilled. We will do this by understanding the legislation, regularly reviewing it, and ensuring robust measures to comply with it. To comply with GDPR, this Information Security & Privacy Policy makes clear that we process our client’s data on the legal basis of Consent and Contract, in order to provide the requested services to them. If we need to contact clients on the legal basis of Legitimate Interest, The Data Protection Lead completes a Legitimate Interests Assessment (LIA). Users are required to follow the company’s practices in the use of secret authentication information.
Electronic data is backed up to preserve its integrity, and information processing facilities are protected within a physical security perimeter. The secure area of our office is protected by appropriate entry controls that only authorized personnel are allowed to access.
Responsibility for the successful implementation of this policy, in practice, lies with the Managing Director, who is in charge of access control (including equipment) and who must approve use of removable media and teleworking. All employees at Anglesey Associates Ltd understand that they have a responsibility to adhere to Processes and to seek to continually improve the efficiency and quality of the protection of information. All staff receive awareness education and training in information security.
The company makes no automated decisions about data processing. We keep client’s information only in order to provide services to them. If a client no longer wishes us to keep their data, we will keep it only so long as we are legally obliged to do so and then destroy it once we are legally able to. A client’s data is never shared with third parties (unless the law obliges us to do so). The data subject has the right to contact us at any time to request details of what data we hold about them, and can request – as stated above – that we no longer hold the data. They can also request that we update their data, where corrections to the facts may be applicable. Any complaints may be made to the Managing Director, who will respond promptly.
In line with GDPR, a Data Subject has the right to be informed; the right of access; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; the right to object; and the rights in relation to automated decision making and profiling. See Section 3 below for more details.
Copies of our Roles, Responsibilities & Authorities Matrix, our Processes and ISO Certification can be forwarded to interested parties on request.
Anglesey Associates Ltd (registered in England and Wales under company registration number 13878631) are the controller and responsible for your personal data (collectively referred to as “Anglesey Associates Ltd”, “Company”, “we”, “us” or “our” in this privacy policy).
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes our policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Anglesey Associates Ltd is committed to safeguarding your privacy. Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
By using this site or / and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.
TABLE OF CONTENTS
1. DEFINITIONS
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us – (either capitalized or not)
2. DATA PROTECTION PRINCIPLES
We endeavour to follow the following data protection principles:
Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
Processing is limited with a time period. We will not store your personal data for longer than needed.
We will do our best to ensure the accuracy of data.
We will do our best to ensure the integrity and confidentiality of data.
3. DATA SUBJECT’S RIGHTS
The Data Subject has the following rights:
Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
If you wish to confirm that Anglesey Associates Ltd is processing your personal data, or to have access to the personal data we may have about you, please contact us at: alex@angleseyassociates.com
4. DATA WE GATHER
Information you have provided us with
This might be your e-mail address, business contact name, billing address and business contact number – mainly information that is necessary for delivering our service to you or to enhance your customer experience with us.
We have your contact details (Our Account Number, Contact Name, Contact e-mail, Contact Telephone Number, Business Address) on a client database and will not disclose this information to any third-party without your consent.
Any marketing or information e-mails sent to our Clients will be done using the Blind Carbon Copy (Bcc.) send option, therefore e-mail addresses can be hidden from others.
We may also periodically conduct business and individual user surveys because they provide us with important information that helps us to improve our services. Participation in such surveys is completely voluntary and you, therefore, have a choice whether or not to disclose this information.
Data you submit online through our Contact Form may also be combined with other information you provide through other means of communication, such as postal mail.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available.
5. HOW WE USE YOUR PERSONAL DATA
We use your Personal Data in order to:
Provide our service to you. This includes for example registering your account; providing you services that you have requested; providing you with special offers, and promotional items on your request and communicating with you in relation to those services; communicating and interacting with you; and notifying you of changes to any services.
Provide you with a quotation or information about our services on your request.
Enhance your customer experience.
Fulfil an obligation under law or contract.
We use your Personal Data on legitimate grounds and / or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
to identify you.
to provide a quotation on your request with the possibility of entering into a contract.
to provide you a service or to send / offer you a product.
when you contact us with the intention to enter into a contract with us, we will then respond to your query on the basis of contractual necessity.
to communicate either for sales or invoicing, or administration relating to a contract.
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
To send you personalised offers.
Where you have contacted us with a query, we will use your personal information to respond to your query as it is necessary to protect our legitimate interests – this is to provide you with good customer service, perhaps giving you additional information on how we can support you and we hope this will lead to us working together in the near future.
To administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of services offered and/or provided.
To conduct questionnaires concerning client satisfaction.
As long as you have not informed us otherwise, we consider offering you services that are similar or same to your purchasing history / browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
to send you newsletters and campaign offers from us.
for other purposes for which we have asked your consent.
We Process your Personal Data in order to fulfil obligations rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
the link between purposes, context and nature of Personal Data is suitable for further Processing.
the further Processing would not harm your interests and
there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
6. WHO ELSE CAN ACCESS YOUR PERSONAL DATA?
We will not share your information with any third parties for the purposes of direct marketing. Personal Data about you is in some cases provided to our trusted partners in order to provide elements of our service to you, to make providing the service to you possible, or to enhance your customer experience.
We may pass your personal data on to third-party service providers contracted to Anglesey Associates Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Anglesey Associates Ltd’s processes. If we wish to pass any form of sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
We share your data with:
Our processing partners:
· Google Analytics – This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site, so that we can improve the quality of information we provide to you, and services we offer to you.
BING Analytics – This website also uses Bing Analytics, a web analytics service provided by Microsoft. Bing Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site, so that we can improve the quality of information we provide to you, and services we offer to you.
We do not otherwise reveal your personal data to third parties for their independent use unless:
you request or authorise it.
the information is provided to comply with the law.
to address emergencies or acts of God; or
to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.
Anglesey Associates Ltd’s website uses interfaces with social media sites such as Facebook, LinkedIn and Twitter. If you choose to “like” or share information from the website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
7. HOW WE SECURE YOUR DATA
To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities. When technically feasible, Anglesey Associates Ltd will – at your request – provide your personal data to you or transmit it directly to another controller.
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
8. CHILDREN
Anglesey Associates Ltd does not knowingly collect personally identifiable information from users under the age of 13. Children under 13 should not send any information about themselves to Anglesey Associates Ltd. If a child under 13 submits information through any part of the Web Site, and Anglesey Associates Ltd becomes aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible.
9. COOKIES AND OTHER TECHNOLOGIES WE USE
We use cookies and / or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us. Insofar as those cookies are not strictly necessary for the provision of our services and correct operation of our website, we will ask you to consent to our use of cookies when you first visit our website.
A cookie is a small text file that is downloaded onto devices such as PCs and Smartphones you use to access a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. Cookies store information that is used to help make websites work. You can control your cookies by changing the settings on your browser. Choosing to disable cookies may hinder your use of certain website functions.
We use cookies for the following purposes:
Necessary cookies – required for the basic functioning of this website.
Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting, or remembering your language preferences or using your country location to set language preferences.
Analytics cookies – these cookies are used to track the use and performance of our website and services.
You can remove cookies stored in your computer via your browser settings. For more information about cookies, visit allaboutcookies.org.
When you visit our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the website. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.
10. CONTACT INFORMATION
Data Protection Officer
Anglesey Associates Ltd has its headquarters in 71-75 Shelton Street, Covent Garden, London, UK and has appointed an internal data protection officer for you to contact if you have any questions, queries or concerns about our personal data policies or practices. Anglesey Associates Ltd’s data protection officer’s name and contact information are as follows:
Name: A. Lovell-Smith
71-75 Shelton Street
Covent Garden
London
United Kingdom
Email: alex@angleseyassociates.com
11. COMPLAINTS
If you have any concerns about how your data is being processed by us or any of our third parties, please contact us and we will attempt to resolve any issues. For the purpose of information security, Anglesey Associates Ltd is governed by the Office of the Information Commissioner (ICO) in the United Kingdom. In the event that you wish to make a complaint about how your personal data is being processed by us or any of our third parties, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority, The Information Commissioners Office (The ICO) details as below:
Supervisory Authority
The Information Commissioners Office (The ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
website: https://ico.org.uk
12. CHANGES AND UPDATES TO THIS PRIVACY POLICY
By using our Site, you agree to the terms and conditions contained in this Privacy Notice and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use our Site. You agree that any dispute over privacy or the terms contained in this Privacy Notice and Conditions of Use, or any other agreement we have with you, will be governed by the laws of the United Kingdom. You also agree to arbitrate such disputes within the United Kingdom, and to abide by any limitation on damages contained in any agreement that are stipulated by the Supervisory Authority.
We reserve the right to amend the Privacy Notice and Conditions of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice and Conditions of Use at this Site. We may email periodic reminders of our notices and terms and conditions and will email Anglesey Associates Ltd customers of material changes thereto, but you should check our Site frequently to see the current Privacy Notice and Conditions of Use that is in effect and any changes that may have been made to it. Historic versions can be obtained by contacting us.