PRIVACY POLICY – CLIENTS AND THIRD PARTIES 

Sphion Ltd is committed to protecting the personal information of our visitors to our studio and website, clients – current and future, suppliers and contractors.

This privacy statement provides information about the personal information that Sphion Ltd collects about all external and third parties such as visitors to our studio and website, clients – current and future, suppliers and contractors, and the ways in which our practice uses that personal information.

Any questions regarding this Policy and our privacy practices should be sent by email to info@sphion.co.uk or by writing to: 

 

The Data Controller

Sphion Ltd.

340 Firecrest Court

Warrington, Cheshire

WA1  1RG

 

How do we collect information from you? 

Our website

You can visit our website without providing any personal information, however we may automatically collect IP addresses, information about your visit and how you use our website.

You may provide us with information by corresponding with us by phone, email, or otherwise as indicated on the website.

The personal information we collect and hold

Website data: We will collect data such as your name, address, email address and telephone details on enquiry form completion.

How we use and disclose personal information

We use your personal data for the following purposes:

  • Accessing a contact form and responding to an enquiry

How long will we hold your personal information?

Where we have personal information which you have consented for us to use, we will hold it for the period the consent remains in force and any other period we need for regulatory or other legal reasons.  You may remove your consent at any time.

To add, update or delete any information we hold please contact us on the details below. We’ll then update your records if we can.

Please see below in relation to your rights to have data erased, rectified or for you to access it and for you to object to any processing or to transfer it.

Your Rights

You have a number of rights in relation to your personal information.

These are:

  • The right to confirm if we are using data about you and to access details about what we are using and how;

  • The right to lodge a complaint with the Information Commissioners Office;

  • The right to request we rectify any inaccurate data corrected or to have data completed which is incomplete for the purpose we hold it;

  • The right to be forgotten. This is the right to ask us to delete information about you and if it is appropriate to do so we will do so;

  • The right to restrict what we do with data in specific circumstances, including where the accuracy of the data is contested, and processing is unlawful but you do not want us to erase the data or if we only need the data to meet legal requirements;

  • The right to receive the data we hold about you in a format you can use to transfer the data electronically elsewhere.

You are also able to withdraw any consent you have provided for use to use your data at any time.  This is opting out and the process is set out below.

General

Your privacy and data protection is very important to us and we comply with all aspects of the Data Protection legislation and ensure that any third parties we engage with do so. You can find out more about your rights to data from the Information Commissioners Office.

We’re based in the UK and your information will not be transferred outside the European Economic Area.

Cookies

When you visit our websites, we may store some information (commonly known as a “cookies”) on your computer. Cookies are pieces of information that a site transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords are not stored in cookies.

How we use cookies

A cookie helps you get the best out of our website and helps us to provide you with a more customised service, whilst using our site.

Cookies expire once you close your browser

You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but if you choose to do so you will not be able to access most parts of our website which are reliant on the use of cookies to operate efficiently and will not work if you set your browser not to accept cookies.  Please note that if you set your browser to reject cookies you may not be able to use certain aspects of our websites.

Anonymous Site Statistics

We may automatically collect non-personal information such as the type of internet browsers being used to view our site. You will not be identified from this information and it is only used to assist us in providing an effective service on our site.

Contact Us

If you have any enquiry relating to your personal information, you can do so by sending an e-mail to us at info@sphion.co.uk  -  (Please note that because of the insecure nature of emails, we cannot accept any responsibility for data lost or intercepted in transit.)

Working with our practice  

Meetings 

When you visit our studio, you will be asked to provide your name and the company you work for. This information is held for safety reasons so we know who is in the building at any one time. However, all studio visits are cancelled until further notice due to Covid-19 and recent Government advice.

Events  

If you are visiting for an event which is being held in our studio, you will be asked for your name and the company you work for.  You may also be provided with a name badge, if appropriate for the event, and asked for consent for your photo to be taken if applicable. If this is the case, photography may be used on our social media sites and publications.  

 

Engaging us in a contract 

When you appoint us to fulfil a contract (if a client) or we appoint you to provide us with a service (if a sub-consultant or vendor), personal data will be exchanged by both parties to ensure regular communication, progress and development in fulfilling any obligations.

What type of information is collected from you? 

The personal information you provide may include your name, company address, e-mail address, phone number and other information about yourself to enable us to provide you with our services.

 

How is your information used? 

When we collect personal information from our clients and other members of the public, it will be used for the following purposes:

  • To maintain responsible commercial relations with you

  • To understand your service and/or project needs

  • To manage and develop our business and operations

  • To meet legal and regulatory requirements

  • To notify you of changes to our services

  • To process a job application if appropriate 

  • To recommend your product or service to relevant contacts within the industry

We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity. 

When you voluntarily give us your personal information we will only use it for the above purposes. If we intend to use your personal information for a purpose other than those above, we will seek your express consent. 

 

Who will it be shared with?

We will not share your information with third parties for any reason other than those specified above.  

 

Your rights

You have the right to ask us not to process your personal information. You can exercise the right by contacting the Data Controller via info@sphion.co.uk.

Our website contains links to a number of websites that may offer useful information to our visitors. Please note that if you follow the link to any of these websites, this privacy statement does not apply and we do not accept responsibility or liability for their policies. 

You also have the right to see and correct data that we hold about you. If your details change or any other information we hold is inaccurate or out of date, please contact the Data Controller via info@sphion.co.uk.

 

Security

Sphion Ltd will take reasonable technical and organisational precautions to ensure that your personal information is treated securely.  We will store all personal information you provide on our secure servers.

We use a least privilege access to data approach, restricting access to only those who need to so they can discharge their duties.

In addition, we have deployed a number of systems to ensure your data remains safe, these include:

  • An incident detection, response and user behaviour analytic system running looking for unusual data access or user behaviour.

  • Carry out vulnerability testing on all desktops to ensure that no known issues exist that would allow applications to be hijacked.

  • A program of monthly patch management which ensures desktops and servers stay up-to-date with latest security patches.

  • Carrying out regular phishing testing to ensure users are aware of the dangers of phishing emails; part of this testing includes training.

  • We use firewalls to protect our network boarders to stop our data being breached.

  • All desktops run antivirus and anti-ransomware software.

  • Performing regular backups

Wi-Fi

We provide access to the internet while you are in the studio, which is securely configured to separate our corporate data from internet browsing. As a guest you will be asked to logon to a secure portal that will grant you access to browse the internet only. We do not store any information about your connection or the sites you visit.

 

13 or Under

We do not collect any personally identifiable information from children aged 13 or under without prior verifiable consent from parents/guardians.  

 

Data Breaches and reporting

If it becomes apparent that a potential data breach has occurred, the Company will endeavour to report this to the ICO within 72 hours of becoming aware. This will be the case if the data breach is likely to result in damage to a person’s reputation, financial loss, loss of confidentiality, or major financial or social disadvantage. If the breach is likely to result in a high risk to the rights and freedoms of the data subject, the Company will also contact the data subject without undue delay.  Data breaches will be reported to the Information Commissioner Office (ICO) by calling the dedicated personal data breach helpline on 0303 123 1113.