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 1. Home
 2. Policies and Statements
 3. Data Privacy Notice

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PRIVACY NOTICE

(UPDATED 11TH APR 2022)

At Civica we take data privacy seriously and we are committed to protecting and
respecting the rights of all individuals. We are dedicated to ensuring the
confidentiality and privacy of information entrusted to us and aspire to be
transparent when we collect and use personal data.

This policy relates to Civica, if you are a customer of Civica Election
Services, please click here.

This privacy notice covers the following:-

 * Our Contact Details
 * How Civica collects personal information
 * Civica’s purposes and lawful bases of personal data processing
 * How we store your information
 * Sharing Information
 * International Transfers
 * Your rights
 * Rights related requests
 * How to complain
 * Changes to this Privacy Notice


OUR CONTACT DETAILS

Civica’s Headquarters is located at
Southbank Central (8th Floor)
30 Stamford Street
London
SE1 9LQ
Tel: 020 7760 2800

Civica is registered with the Information Commissioner’s Office, with
registration number Z5268164.

If you have questions or comments about this Privacy Notice or how we handle
personal data, please direct your correspondence either to the above postal
address (marking the envelope FAO – Data Protection Officer), or to
DPO@Civica.co.uk.


HOW CIVICA COLLECTS PERSONAL INFORMATION

At Civica we may obtain personal data directly from individuals in a number or
ways including:

 * When you fill in a form on our website,
 * When you give us your business card,
 * When you become a client,
 * When you submit a job application,
 * When you use our support and service portals,
 * When you email or call us,
 * When you visit our offices or attend events, conferences and meetings,
 * When you subscribe to our newsletters and user groups.
 * When you participate in a white paper research project

Civica may also obtain personal information indirectly from a variety of sources
including:

 * Third parties, such as joint marketing partners and data brokers that share
   business contact information with us.
 * Recruitment services will provide us with CV’s,
 * Existing clients may share their employees contact details with us,
 * Publicly available sources such as LinkedIn, Companies House or freely
   available news articles,
 * Companies providing security background checks,
 * CCTV located at Civica offices,
 * Reports that are raised through our whistleblowing process

We will always ensure you know we are processing your personal information
except where it is disproportionately difficult to do so.


CIVICA’S PURPOSES AND LAWFUL BASES OF PERSONAL DATA PROCESSING

Civica processes personal data for the following reasons:

TO FILL JOB VACANCIES

If you submit a job application either directly or through a recruiter, we will
use your information in connection with the specific job that you have applied
for and, in the event you are unsuccessful in your application, we will keep
your information on file in case additional vacancies come up for which you may
be suitable.  We store the information of unsuccessful candidates for 6 months.
If you give us your consent to hold it for longer, we will keep this for a
maximum of 2 years.

Sometimes we use publicly available sources of data such as LinkedIn in order to
source candidate’s information. 

The legal basis for processing your data for recruitment is our legitimate
interest in operating our business and fulfilling vacancies.

Prior to the interview process, we will ask whether you need modified access
because of disabilities. Our legal basis for processing this information is
legal obligation.

TO PROVIDE CUSTOMER SUPPORT AND ACCESS TO SELF-SERVICE PORTALS AND TO PROVIDE
SERVICE DELIVERY

When you become a partner / customer of ours, we collect your data from our
portal login pages. We do this in order to provide online and telephone support
services to help deliver contracted services to you via web portals, email or
over the telephone. We use this information to process online requests, solve
problems, answer questions and respond to communications from individuals and
organisations.

If you have access to parts of our websites or use our on-line services, you
remain responsible for keeping your user ID and password confidential.

Our legal basis for processing these data is our legitimate interest in
providing our services.

FOR PURPOSES OF FINANCIAL MANAGEMENT

We gather and retain business contact details for financial management purposes.
Personal information such as names and contact information will be needed to
ensure purchase orders, requisitions, invoices and debts are handled
appropriately. 

Our legal basis for processing financial information is the performance of a
contract. Retention period for this type of information is up to 7 years in line
with legal and tax regulations.

TO SEND YOU MARKETING MATERIALS BY EMAIL

We use your contact to send you marketing and product information. You can opt
out of marketing messages at any time.

We will remove your details from our marketing list if there is no activity
(such as opening an email) for a 3 year period.

We only send marketing information to corporate subscribers (business emails).
From time to time, we may supply some of our marketing lists to our trusted
third-party brokers (prior to purchasing a list). This is to allow them to
cross-reference both lists, ensuring that we receive accurate and up to date
information.

Our legal basis for this processing is our legitimate interest in promoting our
business.

TO TELL YOU ABOUT OUR PRODUCTS AND SERVICES

If you complete an enquiry form on our website or give us your details in
person, for example at a conference, we will contact you by email or phone so
that we can discuss the products or services in which you have indicated an
interest.

As a Civica customer you may wish to join our special interest and user group
forums. These are groups of people that share a common interest in Civica
products and services. In such cases Civica will store personal contact
information such as name & email address to facilitate the organisation of group
events and meetings. Civica may share this personal information amongst other
group members to aid in discussions, knowledge sharing and distribute
information relating to new products that the group may be interested in. Our
lawful basis for processing is our legitimate interest in selling our products
and services.

TO INVITE YOU TO CONFERENCES OR EXHIBITIONS

We use your data to invite you to conferences and events. Sometimes Civica uses
this information to provide assistance with travel and/or hotel arrangements at
the request of the individual.

Our lawful basis for processing data for these purposes our legitimate interest
in promoting our business.

TO HOST MEETINGS WITH YOU AT CIVICA OFFICES, CONFERENCES OR EXHIBITIONS

We need to process your data in order to manage access and physical security at
our offices. At some Civica sites visitors may be required to provide photo
proof of id, but this information will not be stored. Our lawful basis is our
legitimate interest in ensuring the security of our business premises and
authorised attendance at our events.

Additionally, during the COVID-19 pandemic, we will record the dates and times
you visit a Civica facility. We will also collect a contact number from you (or
the nominated lead, if you are part of a group) in the event that this may be
needed to support the contact tracing scheme. This data is only retained for a
period of 21 days.

Our lawful basis for processing data for this purpose is our legitimate interest
in supporting the NHS Test & Trace programme.

We may also ask for dietary restrictions or access requirements that reveal
religious beliefs or physical health conditions. Our legal basis for processing
these data is your consent which you can withdraw at any time.

Once your access has been arranged, we do not retain this information.

TO MANAGE THE SECURITY OF OUR FACILITIES

Some of our offices have CCTV systems that monitor the perimeter of the
buildings. These collect location and time based images of you and, sometimes,
of your vehicle in order to our protect buildings and assets from damage,
vandalism or another crime.

Our lawful basis for the processing this data is legitimate interest to ensure
the security of our business premises and help to prevent and detect crime.

Our policy is to automatically overwrite CCTV footage within 60 days.

TO ALLOW MEMBERS OF THE PUBLIC TO PARTICIPATE IN WHITE PAPER RESEARCH PROJECTS

If you agree to take part in either an Engagement Solutions research project or
a research project on behalf of one of our customers, your data may be used to
produce an industry white paper, thought leadership report, or set of research
findings which may published either by us or our customer and as such in the
public domain.

Our legal basis for this processing is our legitimate interest in promoting our
business.

TO COMPLY WITH AUDITING REQUIREMENTS

In order to maintain our certifications and to comply with our legal
obligations, Civica is required to assist and cooperate with external
third-party auditors. We may need to share your information as part of these
audits.

Our legal basis for this processing is our legitimate interest in maintaining
our business .certifications and standards.

TO TRAIN AND DEVELOP OUR STAFF

We record calls that are made to our customer service centre to assist in our
review of call quality standards. We use this information to help train and
develop our staff.

Call recordings are retained for a period of 90 days before they are
automatically deleted.

Our lawful basis for processing data for these purposes is our legitimate
interest in improving our call quality standards.


HOW WE STORE YOUR INFORMATION

Civica is dedicated to keeping your data safe. We are certified under ISO27001
as having put technical and organisational policies and procedures in place to
protect personal data from loss, misuse, alteration or destruction. We ensure
that access to your personal data is limited only to those who need to access it
and those individuals are required to maintain the confidentiality of such
information. Where necessary, we apply encryption and anonymisation techniques
in efforts to further protect personal data.


HOW LONG WE KEEP PERSONAL DATA

We retain personal data for no longer than necessary for the purposes for which
it is processed, unless we are required to do so by law.

Where appropriate, we may retain personal data for the establishment, exercise
or defence of legal claims.


SHARING INFORMATION

We will never sell your data to third parties. We may, however, share your data
with companies with whom we have a direct business arrangement in order to
jointly market Civica related products.

We also use third party data processors who provide marketing, marketing
automation and lead-generation services for us. We have contracts in place with
our data processors. This means that they cannot do anything with your personal
information unless we have instructed them to do it. They will not share your
personal information with any organisation and they will hold it securely and
retain it for the period we instruct.

The legal basis for sharing these data is our legitimate interest in cost
effectively marketing our business.


INTERNATIONAL TRANSFERS

Civica operates and provides services from its locations across the globe. As
such we may transfer personal information to Civica group locations outside of
the UK when we have a business reason to do so. We have Intra-Group Transfer
Protocols in place based on Standard Contract Clauses which provide legal
safeguards for such transfers, where applicable.

Additionally, in order to support the provision of our services, we may transfer
personal data to our third-party service providers outside the UK. We only
transfer this data where it is necessary to do so and where a legal safeguard is
in place.


YOUR RIGHTS

Your right of access –You have the right to ask us for copies of your personal
information. This right always applies. There are some exemptions, which means
you may not always receive all the information we process.

Your right to rectification – You have the right to ask us to rectify
information you think is inaccurate. You also have the right to ask us to
complete information you think is incomplete. This right always applies.

Your right to erasure – You have the right to ask us to erase your personal
information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to
restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the right to object to processing
if we are using legitimate interests as our lawful basis for processing.

Your right to data portability – This only applies to information you have given
us. You have the right to ask that we transfer the information you gave us from
one organisation to another, or give it to you. The right only applies if we are
processing information based on your consent or as part of a contract, or in
talks about entering into a contract and the processing is automated.

Your right to withdraw consent – You can withdraw your consent that you have
previously given to one or more specified purposes to process your personal
data. This will not affect the lawfulness of any processing carried out before
you withdraw your consent. It may mean we are not able to provide certain
products or services to you and we will advise you if this is the case.


RIGHTS RELATED REQUESTS

We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information or to exercise any of
your other rights. This helps us to ensure that personal data is not disclosed
to any person who has no right to receive it.

No fee is required to make a request unless your request is clearly unfounded or
excessive. Depending on the circumstances, we may be unable to comply with your
request based on other lawful grounds.

There are circumstances, where we have an obligation, legal or otherwise, or the
right to process your personal information, and therefore your request may be
challenged or denied where we believe there is good cause to do so.


HOW TO COMPLAIN

If you disagree with how we are processing your data, please contact our DPO at
DPO@civica.co.uk or address your letter to the DPO at the Civica Headquarters
address listed in the ‘Contact Details’ section.
You can also complain to the ICO if you are unhappy with how we have used your
data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113


EU REPRESENTATIVE

Civica has appointed an EU representative in accordance with Article 27 of the
EU GDPR. Their contact details are as follows:

The DPO Centre Europe Ltd
Alexandra House
3 Ballsbridge Park
Dublin, D04C 7H2
Ireland
civicaeurope@dpocentre.com
+353 1 631 9460

Where applicable, we will share your contact details with our EU representative.


CHANGES TO THIS PRIVACY NOTICE.

Civica will occasionally update this privacy notice to reflect changes in
legislation, our practices and services. When we post changes to this privacy
notice, we will revise the “last updated” date at the top of this privacy
notice. If we make any material changes in the way we collect, use, and share
personal data, we will notify you by prominently posting notice of the changes
on the website. We recommend that you check this page from time to time to
inform yourself of any changes in this privacy notice.

 


SUMMARY OF CHANGES:

Update Detail 27/05/2020 Amended retention information for job vacancies and
marketing processes. 28/07/2020 Clarification of marketing for corporate
subscribers only. Expanded upon requirement to share data with external
auditors. 30/07/2020 Highlighted personal data used for contact tracing
purposes. 15/02/2021 Updated references to legislation to recognise UK GDPR.
04/03/2021 Expanded upon our reasons for relying on legitimate interest.
08/04/2021 Included details of our EU Representative. 12/07/2021 Clarification
of when personal data is shared with third-party auditors. 01/10/2021
Clarification of retention periods 05/11/2021 Extended upon our marketing
processes 20/01/2022 Included data processed via our whistleblowing process
11/04/2022 Clarification on data being used in connection with legal proceedings


LEGAL

 * Accessibility
 * Cookie Policy
 * Email Preference
 * Modern Slavery Statement
 * Policies and Statements
 * Privacy Notice
 * Terms and Conditions


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 * COVID-19
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 * Instagram



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