Privacy and Cookie Policy

Updated: September 12, 2018

This Privacy Notice explains how Oyster IMS collects, stores, manages and protects your personal data. It outlines the types of data that we hold and how we use them. Oyster IMS takes its responsibilities around the correct collection, use and destruction of the personal data of its various audiences very seriously and is committed to openness and fairness in the handling of personal data. We aim to be clear when we collect information about you and not do anything you wouldn’t reasonably expect.

Oyster IMS is the Data Controller (as defined by the Data Protection Act 1998 and all applicable laws which replace or amend it, including the General Data Protection Regulation) who will collect and process your personal data.


1. Who we are

Oyster IMS is a private limited company registered in the UK.


2. Our activity

Oyster IMS offers advisory services and software to public, private and third sector organisations.


3. What personal data do we collect about you?

Oyster IMS collects and processes personal data to support the activity of the organisation. This data is obtained:
• From clients and prospects in the course of our client engagements and during the sales and marketing process
• Within applications from individuals who wish to work with us
• From our suppliers and business partners

Set out below is a list of the personal data we collect:
Personal data we collect from our clients and prospects
• Name
• Business email
• Business phone number
• Company name
• Job title
• Business division
• Reporting Manager
• Office location
• Signature

Personal data we collect from individuals who wish to work with us
• Name
• Home address
• Home phone number
• Personal email
• Personal phone number
• Gender
• Education and training history
• Languages
• Job application details
• Previous work history
• Salary expectation
• Professional memberships
• Qualifications and certifications

Personal data we collect from our suppliers and business partners
• Name
• Business email
• Business phone number
• Job Title
• Company Name
• Office location
• Previous work history
• Bank Account Information
• Professional memberships
• Qualifications and certifications
• Expenses
• Travel Bookings


4. Sensitive personal data

We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, we will always ask for your consent to collect this information which can be freely refused.


5. How do we collect the data?

The majority of the information we process is obtained directly from you and the organisations we work for. We will also obtain your information when we use cookies on our websites (see below).


6. Cookies

For information about cookies, please click here.

Cookie Settings



7. How will we use your information?

We use the information you give us to:
• Send you any newsletters and updates that you have subscribed to
• Provide you with the services and the information about our services that you have requested
• Administer any user accounts we set up for you such as for our support service
• To otherwise communicate with you regarding our aims and activities
• To keep your data up to date
• To implement any instructions, you give us with regard to withdrawing consent to send marketing information
• To use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries
• For internal record keeping so as to keep a record of your relationship with us
• To fulfil contracts you have entered into with Oyster IMS


8. Marketing communications

When and what do we communicate?
Oyster IMS will only contact you for marketing purposes, for example keep you up to date on our work, where we have your consent, or where we are otherwise allowed to do so.
or we are otherwise allowed to do so.
We will make it easy for you to tell us if you would like to receive communications from us and hear more about Oyster IMS work and the ways in which you would like to receive this information such as email, newsletter or post.
We will not send you marketing material or communications if you tell us that you do not wish to receive it. There are a variety of ways you can do this and these are detailed below.
Where you give us your consent to send you marketing information, you may opt out of this at any time. We review our retention periods for personal information on a regular basis, and we frequently encourage you to update your preferences, so you only receive news and opportunities you would like to hear about. You can update or withdraw your consent at any time.

Other circumstances in which you may receive communications from Oyster IMS
‘Soft opt in’
This allows organisations to send communications by email to individuals, who we have an existing relationship with, and where we have identified that we have a legitimate interest in communicating about Oyster IMS, provided they are given the opportunity to opt out at the time of initial communication or engagement.

How to control what we send you or request we update your personal information?
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.
If you wish to change how we communicate with you, or update the information we hold, then please contact us:
• Email us at info@oyster-ims.com
• Write to us at: Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY
• Telephone: 020 7199 0620
• Additionally, you can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from Oyster IMS

How long will it take for these changes to be effective?
We endeavour to make updates to the marketing preference within:
• 24 hours from updates to preferences via the link in our email
• 5 working days from receipt of email, call or letter


9. Who do we share your information with and why?

• Oyster IMS will only use the information within the organisation for the purposes for which it was obtained. We will not under any circumstances, share or sell your data with any third party for their own purposes, and you will not receive marketing from any other organisations as a result of giving your details to us.
• We may share your information with:
o Third parties who supply services to us or process information on our behalf such as our website developer, event organisers and publishers.
o Assessors, auditors and regulators as required by legal obligation or internal governance
o Oyster IMS partners and associated organisations
These “data processors” will only act under our instruction and are subject to contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
We will share your information if we are required to by law (for example to law enforcement agencies for the prevention or detection of crime, subject to such bodies providing us with a relevant request in writing).


10. Where do we keep your data?

Oyster IMS maintains all your data within the EU.
Data would only be processed by third parties outside of the EU for the provision of services such as:
• Managing events outside of the EU
• Technical service support
• Order fulfilment outside of the EU

Where data is processed outside of the EU Oyster IMS has verified that appropriate safeguards are in place including:
• Complying with all data protection principles
• Where possible trying to ensure data is processed in a country that is on the list of countries approved as adequate by the EU
• If the transfer is to an organisation in the United States of America ensuring that the organisation participates under the relevant data sharing legislation
• Ensuring that in all other instances adequate contractual provision are in place to ensure the protection of the data


11. How long do we keep your data?

We will hold your personal data in our systems for as long as is necessary for the relevant activity. These purposes are laid out in the section ‘How we will use your information’.

Financial records will be retained in line with financial law and regulation for at least seven years.

If you request that we stop sending you marketing materials, we will keep a record of your contact details to enable us to comply with your request not to be contacted.


12. How do we protect your data?

We ensure that there are appropriate technical and operational measures in place to protect your personal data. Oyster IMS holds the UK government’s Cyber Essentials Plus Certification.

We have appropriate technical controls in place to protect your personal data:
• Our network is protected behind firewalls
• Anti-virus and Malware software is deployed
• All systems are password protected
• Our network is monitored by security specialists
• Network protection is formally tested
We have appropriate operational measures in place to protect your personal data:
• We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors.
• Where we use external companies to collect or process personal data on our behalf, we do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf or have access to.
• We have a robust audit framework in place to ensure internal and external measures and obligations are in place and being maintained.


13. Your rights relating to your personal data

There are specific rights enshrined in law that you have around your data. These rights are:
• Informed – you have the right to be informed about what data we hold and for what purpose
• Access – you have the right to have access to your personal data
• Rectification – you have the right to have your personal data corrected or removed if it is inaccurate
• Erasure – you have the right to have your personal data deleted from our systems
• Restrict processing – you have the right restrict the processing of your personal data
• Right of objection – you have the right to object to the processing of your personal data for communications and marketing
• Portability – you have the right to have your personal data transferred
• Withdraw consent – where you have provided consent to process your personal data you have the right to withdraw that consent at any time
• Complain – you have the right to complain to the regulator and/or seek judicial remedy if your data has not been treated in accordance with the law

We will respond to you within one month of receiving a request related to anyone of the above rights unless the number and complexity of the requests made is deemed sufficiently high in which case we may extend this time by a further two months. We will inform you if we need to make use of this additional time and why we need to do so.

We will not charge you for responding to any of these requests unless it can be demonstrated that you are making an excessive number of repetitive requests or that your request is not based on fact or realistic considerations. In such exceptional cases we may charge you a reasonable fee or choose to refuse your request.

If you disagree with our approach you may raise your concerns with the Information Commissioner’s Office (ICO) https://ico.org.uk/concerns/
To assist us in responding to these requests, we may ask you to verify your identity to make sure we do not give your personal data to the wrong person, update your data with details you did not provide or take action you did not request.

Right to be Informed
Oyster IMS has published this Privacy Notice along with additional notices when we collect personal data from you to explain what personal data we collect and process. We aim to be as open and transparent as possible about how we use your personal data.


Right of Access

You have the right to request a copy of the personal information that we hold about you.
If you would like a copy of some or all of your personal data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right of Rectification
It is important to us that the information we hold about you is accurate and up to date. If you believe that the information we hold is inaccurate or incomplete you have the right to ask us to rectify it. If we have passed your data to a third party for processing, then we will also contact them to rectify the data.
To request the rectification of your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right of Erasure
This is sometimes referred to as the “Right to be forgotten”. You can request that we delete your personal data from our systems if you:
• Believe the data is no longer necessary for the purpose for which it was collected
• Withdraw your consent (subject to the requirement for us to retain data to process your request)
• Believe we have processed your data unlawfully
• Believe we should delete your data to comply with other laws or regulation
• We may choose to refuse your request if we believe:
o We have a legal obligation to keep your data
o It is required for the legitimate interests and purposes of Oyster IMS
o It is required for the establishment, exercise or defence of legal claims
To request the erasure of your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right of Restriction
You have the right to ask Oyster IMS to restrict how we process your data. This provides for a temporary halt to processing your data. You may make the request if you believe that:
• We should not process your data whilst we are in discussions with you regarding a disagreement over the accuracy of your personal data, or;
• We have processed your data in a manner you believe to be unlawful but rather than asking for the erasure of the data you would prefer another course of action to rectify your issue, or;
• We no longer require the data, but you do not wish us to dispose of it as you require it to establish or defend a legal claim
• If such as restriction is put in place, we shall limit the processing of your data to storage with the following exceptions
• Where the processing is for the establishment, exercise or defence of legal claims
• We must process it to protect the rights of another person
To request the restriction of processing of your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right of Objection
You have the right to object to the processing of your personal data.
If your data is being used for direct marketing purposes, you have the right at any time to stop us from contacting you as outlined in this notice.
If we are processing your data based on our legitimate interests, you may seek to object to the processing of your personal data.
We may reject your request:
• Where we believe we have compelling legitimate grounds for continuing to process your data which outweighs any harm or damage to you through the continued processing of the data
• Where the processing is for the establishment, exercise or defence of legal claims
To object to the processing of your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right of Portability
Oyster IMS must allow you to obtain and reuse your personal data for your own purposes. This applies to personal data you have provided to us and is processed in our computer systems. You can request that we provide you with a copy of this data in a format that can be read by another person’s or organisation’s computer system.
You have the right to transfer that copy of your data to another organisation or request that we do it for you where it is technically feasible for us to do so.
This right of transfer can be refused where we feel it may adversely affect the rights of another person.
To request the transfer of your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right to withdraw consent
Where we rely on your consent for the processing of your data you have the right to change your mind and withdraw your consent at any time. If you withdraw your consent, we must stop processing your data.
To withdraw your consent for processing your data please email us at info@oyster-ims.com or write to Privacy Team, Oyster IMS, The Loom, 14 Gower’s Walk, London E1 8PY with details of your request.

Right to Complain
You have a right to complain to the Information Commissioner’s Office (ICO) if:
• We do not take action on your request within one month of receipt and do not provide you with reasons why
• You believe that the way we are processing your data is not in keeping with the requirements of the law
• You believe your rights have been infringed because of the way we have processed your data
Please see the following section for contact information.


14. How to contact us or raise a concern or complaint

Contacting Oyster IMS
If you have any concerns about how your personal data is being collected and processed, or wish to exercise any of your rights detailed in this Privacy Notice please contact us at info@oyster-ims.com or write to us at:

Privacy Team

Oyster IMS

14 Gower’s Walk

London

E1 8PY

 

Email: info@oyster-ims.com

Telephone: 020 7199 0620
Contacting the Information Commissioner’s Office
If you have wider concerns about how Oyster IMS manages information or wish to make a complaint, please contact the Information Commissioners Office (ICO). The ICO can be contacted at https://ico.org.uk/global/contact-us/.
Concerns can also be logged via the ICO website https://ico.org.uk/concerns/.


15. Future changes

If our information practices change at some point in the future, we will update this policy. If material changes are made to this notice we will notify you by placing a prominent notice on the website and where we communicate with you through digital media.

We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 12 September 2018.


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