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Data Protection Policy

DELPHI MANAGEMENT PRIVACY POLICY – EXTERNAL

Delphi Management Ltd (“Delphi Management”, “we”, “us” or “our”) consider the privacy and protection of our clients’ data, to be of the utmost importance and we take robust measures across our business to protect the security and integrity of all such information.

This policy sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us when you submit [a new client application form], purchase products or services from us or via us, or make enquiries or otherwise communicate with us.

A copy of this policy can be requested from your Delphi Management representative.

By providing your contact details to us when you make an enquiry (whether by phone, in person or via electronic means), filling in a new client application form, or by indicating you would like services from or via Delphi Management, you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Delphi Management Ltd. Registered office: 48 Queen Street, Exeter, EX4 3SR. Registered number 08584852 (England and Wales).

Our nominated representative for the purpose of the Act is our Data Protection Compliance Manager who may be contacted using the details set out at the Contact Us section below.

Disclosure of your Information

You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your personal information, we may be obliged to do so.

Unless we have your express consent, we will only disclose personal data to third parties as set out in this Privacy Policy or if this is required for the purpose of providing your services or dealing with your enquiry.

We do not sell, rent or trade your personal information to third parties for marketing purposes.
The data that we collect from you is processed by staff who work either for us, for one, of our outsourced service providers. Such individuals or organisations may be engaged in, among other things, the fulfilment of your services, the processing of your payment details and the provision of support services. Where your personal information is disclosed to any of our outsourced service providers for these purposes, they will only have access to the information needed to perform their functions, and our contractual arrangements with them do not permit them to use your personal information for their own purposes.

Where applicable, we may disclose your personal information to any of our business units and, where you have provided us with consent, to the companies in our Network.

Information Delphi Management collects

Delphi Management will use the information that you provide to us to deal with your enquiry or to provide you with services. Delphi Management may, however, process the following data about you that you give to us:

  • Information you give to Delphi Management. Information you give to us about you by filling in a new client form, an existing client details form, or if you or one of our representatives complete an enquiry form, when you speak to or communicate with one of our representatives, when you report a problem with our services.

The information you give us may include your name, address, e-mail address, phone number, national insurance number, bank account details, marital status, residency status, date of birth, nature of profession, number of years’ experience, qualifications, next of kin contact details, bank account details, job title, copy of passport, proof of address, company name, business address, company registration documents, company registration number and VAT registration number.

  • Information Delphi Management already holds about you from our telephone services. If you have used our telephone services previously, we may already hold other information about you.
  • Delphi Management other business units – Delphi Management is the umbrella company for a number of businesses, each of which represent a specialist service area. These businesses use different trading names but operate as one company. Where you have provided information to one of those business units, that business units may provide information to the other business units in order to provide services to you
  • The Delphi Management Network – Delphi Management uses a network of professional service providers which may provide certain services directly to you. If you have provided your consent and instructions to those providers, they may disclose your information to Delphi Management, which we may use to provide our services to you.
  • Outsourced Service Providers – to make our services efficient, and robust, we outsource certain services and we may receive information about you from them.
    Sensitive Personal Data. Unless we make it clear otherwise, our policy is not to ask for any sensitive personal data from you (that is information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences).
  • Information about other people. If you provide information to us about any person other than yourself, such as your next of kin, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, our Network, and our outsourced service providers, to use it.
    You will find that it is not compulsory to provide us with any additional information we request which is not necessary or reasonable in order to provide you with the services you have requested.

How is your personal information used?
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purposes:

  • Information you give to Delphi Management. We will use this information as follows:
    • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
    • If you enter into arrangements directly for services from one of the companies in our Network your information will also be held on computer or other files by that company and any agents or associated company for the purposes of providing that service.
    • If you are an existing client, we may contact you by electronic means (e.g. by e-mail or SMS/ text or push messages to your smartphone) with information about services of ours which are similar to those which you have use previously or negotiated with us about previously. If you have agreed that we may do so, we may also use your personal data to contact you by electronic means with information about other services of ours.
    • To notify you about changes to our products and services;
  • Information you provide to companies in our Network
    • If you wish to enter into an agreement with a company in our Network, we will facilitate this for you, and we will pass your information to the relevant companies. Those companies may be third party data controllers and are therefore responsible for any information that you provide to them. Delphi Management simply enable you to set up a direct relationship with these companies.

Information Delphi Management collects about you. We will use this information:

  • To provide our services, and facilitate the provision of services via our Network companies;
  • To administer our telephone services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our services to ensure that information is provided in the most effective manner for you;
  • To keep information in compliance with our legal obligations.

Information Delphi Management receives from other sources. We may combine the information you give to us with information which we collect about you and information which we collect from third parties about you. We may use this information and the combined information we collect about you for the purposes set out above.

Storing Your Personal Data
Where legal requirements have been complied with we may transfer personal data that we collect from you to locations outside of the European Economic Area for processing and storing. Your data may also be processed by staff operating outside the European Economic Area who work for us or for one of our suppliers. For example, such staff may be engaged in the provision of your services, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to make sure that your data is treated securely and in agreement with this Privacy Policy.

We will retain your information for a reasonable period or as long as the law requires in accordance with our Data Retention and Data Destruction Policies. If you have any questions relating to our retention or destruction of your data, please contact us using the details set out in the Contact Us section below.

In accordance with the Data Protection Act 1998, we employ strict physical, electronic, and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line. Any personal data that is provided to us is stored on our secure servers and/or those of the service provider hosting our site on our behalf.

Access to information and other rights

  • The Act gives you the right to:
    Access information that we hold about you. Your right of access can be exercised in accordance with the Act. If you require any such information, you must submit a written request and pay a fee of £10. We may also require proof of your identity before we supply the information to you;
  • Ask us to prevent processing that is causing – or is likely to cause – you substantial damage or distress;
  • Require us not to make certain decisions automatically if they significantly affect you;
  • Ask us to make any necessary changes to the personal data we hold about you in order to ensure that it is accurate and up to date;

Should you wish to contact us about any of these matters, please use the contact link set out at the Contact Us section below.

Changes to our privacy policy
We may change this Privacy Policy at any time. If we do, we will display a notice to this effect on the home page of our site for at least 30 days. If you use our services or access our site after we have published such a notice, you will be accepting the new policy. Where appropriate, we may also notify you of the changes to you by email.

Contact Us
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Delphi Management Data Protection Compliance Officer at:
Address: Data Protection Compliance Officer, Delphi Management Ltd, 48 Queen Street, Exeter, EX4 3SR
This Privacy Policy was last updated in May 2018.