1. Introduction and about us
The policy gives a general overview of how Armiger processes personal data, but you may receive more detailed information about data protection (including separate privacy policies or notices) depending on the different ways you interact with us. Armiger is the ‘data controller’, that is, the company responsible for, and which controls and processes your personal data). Armiger is subject to the General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018. Any phrase introduced by the expressions “including”, “includes”, “include”, “for example”, or any similar expression shall be construed as illustrative and shall not limit the sense of the words preceding those terms.
2. The Website
www.armgr.com is the official website of Armiger Limited. This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all UK national laws and requirements for user privacy.
3. The categories of personal data we collect and/or receive
Armiger processes a range of information about you. This includes, for virtually all individuals, your name and contact information (such as your home and/or business address (as applicable), email address and telephone number), records of communications and interactions we have had with you by various means, basic biographical information including your date of birth and gender (where relevant), and financial information including bank account details (used for accepting payments from you or making them to you, as applicable).
Personal data processed by Armiger also includes:
- National Union of Students (“NUS”) number / student details (if applicable).
- Medical records, injury information and other health related data.
- Disclosure and Barring Service (“DBS”) information (criminal records checks), where applicable.
- Records of activity such as intern role(s), length of service, awards and number of hours;
- Application or registration details for the purposes of internship;
- Reference checks;
- DBS information, where relevant; and/or
- Availability information.
For the directors of each Armiger entity:
- Contact details; and/or
- Details of your role or involvement in meetings, hearings, investigations, etc.
For website users:
- Login ID information, including usernames;
- Information provided through our website, including in messages and forms, for example forms for updating communication; and/or
- Personal data collected by ‘cookies’ and similar technologies (please see our Cookies Policy for further information)
4. How we collect and/or receive personal data
We may collect your personal information in a number of ways, principally:
- Directly from you, for example when you make enquiries on our website, and when you interact with us either online, for example using our platforms or online resources, or as an intern.
- From someone else acting on your behalf, for example Armiger staff who are working with you;
- From third parties you are connected to, for example:
(i) If you have expressed an interest in receiving information from Armiger;
(ii) As a result of a share or asset purchase by Armiger;
(iii) If you are named as a contact on an invoice or as part of a payment process;
(iv) From your interaction with Armiger accounts on third party platforms, including, for example, Facebook, Twitter, Instagram, and YouTube (for example when you express an interest in Armiger by clicking ‘Like’ on Armiger’s Facebook page or one of our posts);
(v) From national governments, regional and local development centres and other entities working with Armiger’s team;
- From others who are not acting on your behalf (for example, where someone makes a complaint about you which we then investigate);
- By creating it ourselves or where third parties create it for Armiger, for example (i) when we access data from public sources (including, for example, published reports and online data) and analyse it using Armiger’s online platforms, (ii) where individuals working for or on behalf of Armiger create records and reports in relation to clients;
- When your details are provided to us through Armiger registration process.
5. Our basis for processing personal data and the purposes for which we use it
- Performance of contracts. Armiger will process your personal data where this is necessary for the performance of a contract with you, or to take steps at your request before entering into such a contract. For example, we need to process personal data in order to comply with any terms and conditions (applicable to the use of our website), and with Client and personnel agreements.
- Compliance with our legal obligations. In some cases, Armiger needs to process your personal data in order to comply with its legal obligations. For example, we need to process personal data in order to comply with health and safety legislation, carry out DBS (criminal records) checks on officials and intern roles (where relevant) for safeguarding purposes, report certain tax information about our financial arrangements with third parties to HM Revenue & Customs and assist with investigations by police and/or other competent authorities.
- Legitimate interests. In other cases, Armiger has ‘legitimate interests’ in processing personal information about individuals we interact with. We have many such interests, including commercial interests and those with a wider public benefit. For example, we need to process personal data in pursuit of our legitimate interests in order to:
- market Armiger’s products and services
- ensure the security of Armiger personnel, contracts and premises, including by recording individuals’ photographs and processing personal details as part of accreditation processes and capturing individual’s images using CCTV monitoring;
- undertake analysis and research to gain insight into the backgrounds and motivations of relevant individuals, and to improve Armiger’s products and services;
- process queries, complaints or other information received by Armiger;
- keep appropriate records of individuals associated with Armiger, including officials, personnel, interns and Designated Role Holders;
- administer and undertake disciplinary, safeguarding, licensing, accreditation, anti-corruption, anti-money laundering, due diligence or other ‘know your customer’ (KYC) checks and other regulatory and governance functions (including exercising any right, power or authority in terms of Armiger Competition Regulations or Armiger Disciplinary Code), including any review, process and/ or other involvement by the Designated Role Holders, and keep records in relation to or connection with the same, including of any decisions made in respect of these functions;
- administer our performance programme
- Where Armiger relies on legitimate interests as the legal basis for processing personal data, it has considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose data are being processed and concluded that the processing is, on balance, fair.
- Consent. Armiger may also process your personal data on the basis of consent you give, for example to send you certain direct marketing communications, or to place certain ‘cookies’ on your computer or other device when you use our website (please see our cookies policy for more information about this).
- Processing special categories of data. Where we process sensitive personal data, other legal bases for processing may apply, including where our processing is necessary for the establishment, exercise or defence of legal claims (for example, to protect and/or defend our property or rights), for reasons of substantial public interest (to conduct safeguarding investigations and hearings, for the provision of medical care and treatment, for the purposes of equal opportunities monitoring or where you have otherwise given us your explicit consent (for example, to allow the use of medical records for monitoring purposes, or to share those records with another, or where officials provide us with data relating to criminal convictions and offences as part of the DBS disclosure process).
Armiger only offers its services to individuals over the age of 18 and does not intend or expect children to visit the website. When accessing our website you confirm that you have read, understood and consented to this Policy and certify that you are over the age of 18.
6. Who we may share your data with
Personal information collected and processed by Armiger may be shared with the following recipients, or categories of recipients, where necessary:
- Our employees and interns (as applicable), for the purposes of providing particular products or services to you;
- (Where you are an intern) with our employees and other interns, for the purposes of intern management and administration and any intern application or project;
- Third party training course providers whose services you book via Armiger (and, where relevant and appropriate, we may share individuals’ contact details with other training course providers);
- Our contractors and suppliers, where they process personal data on our behalf (for example, IT consultants and hosted software providers, insurers and other product or service providers) including Armiger’s media and strategy partners; benefits providers; and companies assisting Armiger with research and analysis of its products and services;
- DBS and safeguarding committees and ‘umbrella bodies’ (for the purpose of carrying out criminal records checks where relevant), HM Revenue & Customs (for tax reporting purposes), the police, local authorities (including any local authority designated officer (“LADO”)) and/or other competent authorities, as applicable;
- Designated professional advisors, investigators and experts with suitable experience as required to carry out disciplinary, safeguarding, licensing, accreditation, anti-corruption, and other regulatory and governance functions;
- Social media platforms, including Facebook, so that we can engage with you via your Facebook or other social media accounts, including by tailoring the advertisements you see on Facebook based on what we know about you and your particular related interests, and to help us find other Facebook users similar to you who may be interested in what Armiger has to offer; and
- Former employers and other providers of necessary background checks.
Typically, Armiger will not transfer your personal data to countries outside the European Economic Area (EEA) or the UK. On the limited occasions when this does occur (for example, because your personal data is stored on an IT system hosted outside of the EEA or the UK), we ensure that any such transfer meets the requirements of the GDPR. Where we make more regular and/or larger scale transfers of personal data outside the EEA or the UK, we will assess the adequacy of the protections in place for that data to ensure the transfers are lawful. You can obtain more details of the protection given to your personal data when it is transferred outside the EEA or the UK by contacting us using the details below.
7. How long we will store your data
We may retain recordings or transcripts of disciplinary, safeguarding and other hearings. We may also retain a safeguarding related ‘flag’ on our internal records (which is only visible to certain members of staff on a ‘need-to-know’ basis), which indicates when an individual has been involved in a safeguarding incident, regardless of the outcome.
8. Your rights in relation to your personal data
Under the GDPR, you have the right to:
- obtain access to, and copies of, the personal data that we hold about you;
- require us to correct the personal data we hold about you if it is incorrect;
- require us to erase your personal data in certain circumstances;
- require us to restrict our data processing activities in certain circumstances;
- receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of your transmitting that personal data to another data controller;
- object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you; and
- where our processing is based on your consent, withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.
If you would like to exercise any of these rights, please contact us in writing using the contact details below. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.
If you are not satisfied with how we are processing your personal data, you can complain to the Information Commissioner’s Office (ICO). You can also find out more about your rights under the GDPR (and other data protection legislation) from the Information Commissioner’s Office website available at: www.ico.org.uk.
You can at any time withdraw any email marketing consent you have previously provided by selecting the unsubscribe link in any of the marketing emails we have sent you. You may also edit your details. If you wish to edit your details, please refer to the relevant section of Armiger website.
In some cases described above, the provision of personal data is a contractual requirement, and/or a statutory requirement if you wish to engage with Armiger in a certain way (and there is a statutory requirement for us to carry out a criminal records check on you, for safeguarding purposes). In those and other cases, if you do not provide us with certain personal data, we may not be able to work with you or provide our products or services to you (as applicable), or it may adversely affect the provision of our services to you.
We DO NOT SHARE data with any other third parties and it is for our own internal use only.
We will not sell or rent your personally identifiable information, gathered as a result of filling out the site registration form, to anyone.
For information about how Armiger uses ‘cookies’ on our website(s), please see our cookies policy.*
Emailing us at: firstname.lastname@example.org
Telephone us at: +44 20 7478 1640
Writing to us at: Armiger Limited (GDPR department) 17 Carlton House Terrace St. James’s, London SW1Y 5AH
This policy sets out the different areas where user privacy is concerned and outlines the obligations and requirements of the users with regard to cookies.
What are cookies?
We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features. If you log into the website, application or a course as a registered user, your session cookie will also contain your user ID so that we can check which services you are allowed to access.
Should users wish to deny the use and saving of cookies from this website onto their computer’s hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors. We also provide an option for you to disable cookies when you visit our website. This is in the form of a notice, found at the bottom of our website that allows you to disable cookies.
You can unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any emails from us. You can also change your preference settings for email by clicking the link found on every one of our emails.
You can request a readable copy of the personal data we hold on you at any time. To do this, please contact us: email@example.com
Armiger respects your right to determine what communications you receive from us. Please click here if you no longer wish to receive any further notices or correspondence from us.