BLACKWATER
Privacy Statement
Blackwater is committed to respecting and protecting your privacy
We have prepared this privacy statement to disclose and describe our information gathering and dissemination practices for this website.
Notice and Disclosure
In general, you may visit this website without identifying yourself or revealing any personal information. Blackwater collects domain information from your visit to customise and improve your experience on our website.
Registering personal information
Some areas of this website may require you to give us personally identifiable information, which is information that enables us to identify you, such as your name, email or other address. By submitting your information to Blackwater by email, use of the Blackwater web site or otherwise, you consent to the use of that information as set out in this policy. Blackwater may from time to time modify the terms of this policy and any changes will be posted on this page.
Should you provide Blackwater with your contact information (such as name, company, address, and email address) this information will only be used to contact you for the purpose for which you have expressed an interest such as, for example, the services, career opportunities, surveys, seminars or webinars of Blackwater.
Data Security
Whilst Blackwater takes all reasonable precautions to protect personally identifiable information from loss, misuse, alteration or destruction and complies with applicable data protection legislation (including but not limited to the Data Protection Act 2018), data transmission over the internet may not be adequately secured by the sender. As a result, Blackwater cannot ensure the secure receipt of any information that is sent to Blackwater by this medium and any such information is sent at your own risk.
Business Relationships
This website may contain links to other websites. Blackwater is not responsible for the privacy practices or the content of such websites.
Cookies
The Blackwater website only uses cookies as an aid to the user experience to enable a user’s browser to remember user location and pages on the web site that have already been accessed.
Contacting Us
If you have any questions or comments about our privacy statement or practices, please contact us via email at enquiries@blackwateretf.com with the words ‘privacy policy’ in the subject line.
Blackwater reserves the right to modify or update this privacy statement at any time without notice.
Blackwater Privacy Statement
Personal Data – Privacy Statement
This Privacy Statement lays out how Blackwater treats client personal data (where ‘client’ refers to all of the following; client organisation, TPA or Vendor, or third party such as industry bodies), and what rights Blackwater’s clients have in relation to this information.
In respect of the processing of your personal data in line with this Privacy Statement, Blackwater act as a controller for the personal data they process and comply with the associated requirements as laid out under the General Data Protection Regulation (GDPR), the Data Protection Act 2018 (DPA) and other data protection laws and regulations that apply to them. The controlling entity will be Blackwater.
1.1. Categories of personal data
When we refer to “personal data” we mean any data relating to an identified or identifiable individual. This could include information that could identify an individual, directly or indirectly, in particular, by reference to an identifier such as a name, ID number, location data or online identifier. It also includes factors specific to an individual’s characteristics.
Blackwater collects limited personal data on its clients; and this primarily encompasses the following types of information:
• contact and organisation related material such as an individual’s work email and business role;
• business communications, such as email exchanges or online / in-person meetings.
1.2. Sources of personal data
We collect your personal data during the course of your dealings with us. For example, when you engage with us in respect of a project we are undertaking for your organisation. Otherwise, we gather information about you when you provide it to us, for example when you correspond with your contacts within Blackwater.
We may also receive information about you from other sources, such as directly from your organisation or via online resources including LinkedIn and other publicly available sources. We combine information about you from various sources, including the information that you have provided to us directly.
1.3. Purposes of processing
Blackwater collects client personal data for the following purposes:
• to manage past, current and future business engagements;
• to send information such as engagement related proposals and materials, industry relevant information (such as newsletters, insights, video interviews), event invitations;
• direct marketing communications; and.
• to comply with our legal and regulatory obligations.
1.4. Lawful basis for processing
Blackwater collects, uses, processes and discloses personal data in accordance with applicable data protection and privacy laws. We process personal data on the following bases:
• for legitimate business purposes, including ensuring that Blackwater (i) is able to maintain its relationships with existing clients, (ii) is able to manage past, current and future client engagements and (iii) to promote its services and products;
• for the performance of a contract that we have entered into with our client;
• consent, where required by law (including marketing to individuals in a personal capacity by email or SMS).
1.5. Data recipients
Your personal data may be shared with Blackwater’s affiliates throughout the world, and with certain third parties such as:
• service providers that provide services on our behalf, including IT service providers;
• legal and other professional advisors and auditors; and
• regulators and law enforcement agencies.
Where third parties are given access to your personal data, Blackwater will take the required contractual, technical and organisational measures to ensure that your personal data is only processed to the extent necessary.
1.6. Third country transfers
Blackwater may transfer personal data outside of the UK and the EEA, where data protection laws may not offer the same level of protection available in your home country. Personal data may be transferred to third countries outside of the EEA. Where we use third parties to provide data hosting solutions, these transfers comply with relevant equivalent programmes, such as the EU-US Privacy Shield (frameworks developed to enable organisations to comply with data protection requirements when transferring personal data from the European Union to third countries). When we transfer your personal data to any Blackwater affiliates based outside the EEA or any country considered “adequate” by the European Commission to a country that is outside the EEA or an “adequate country”, we rely on an intra-group transfer agreement that incorporates EU Standard Contractual Clauses designed to protect your personal data. You may obtain information and a copy of the relevant mechanism relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” section. You may also find a copy of the EU Standard Contractual Clauses and related information at the Europa website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en)
1.7. Retention period
Blackwater will only hold your personal data for as long as required to undertake the purposes of our processing, plus a prescribed period of time as required by national laws in your jurisdiction.
We hold personal data about our clients for the following periods:
• Data relating to prospective clients will be retained for up to five years, after which the record will be deleted if there is no recorded contact between Blackwater and the prospective client or the prospective client has asked to be deleted within this period;
• Data relating to clients will be retained for the duration of the client relationship plus a further period to comply with certain obligations, legal requirements and best practices.
We will also retain your personal data for as long as necessary in connection with legal action or any investigations involving Blackwater.
1.8. Individual data rights
Individuals may have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, if your personal data is processed by Blackwater in respect of our client relationship activities, you may have the following rights:
• to receive confirmation from Blackwater as to whether we process your personal data, and where we do, access to that personal data and certain other information;
• to request the rectification of any inaccurate personal data that we hold about you;
• to request the erasure of your personal data in certain circumstances;
• to request the restriction of our processing of your personal data in certain other circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
• to receive a copy of the personal data that you have provided to Blackwater in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organisation;
• to object to certain processing of your personal data and to automated decision making and where our processing is based on your consent, you have the right to withdraw consent at any time by contacting us.
Where you are given the option to share your personal data with us, you can always choose not to do so. If you object to the processing of your personal data, we will respect that choice in accordance with its legal obligations. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in the Purposes of Processing section above.
1.9. Right to lodge a complaint with a supervisory authority
Under the GDPR and the DPA, individuals have the right to lodge a complaint with their local data protection authority (in the EEA) or the Information Commissioner’s Office (in the UK). Information about reporting a complaint to the ICO can be found at https://ico.org.uk/concerns/.
A list of EEA data protection authorities by jurisdiction is available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
1.10. Contact us
Please feel free to contact Blackwater if you have any questions about this Privacy Statement or any of Blackwater’s practices in relation to your personal data. Clients should direct requests to their primary contact at Blackwater in the first instance, whether this is to seek further information or to exercise any of your statutory rights.
You can contact us by emailing enquiries@blackwateretf.com
Blackwater Recruitment Privacy Statement