This privacy notice is a public declaration of how Blue Sky (Part of Capita plc, henceforth Blue Sky) applies the Data Protection Principles & Rights afforded to individuals by the GDPR, to the personal data that we process.
Blue Sky is committed to complying to the 6 principles relating to the processing of personal data under the GDPR in all that we do. These principles are:
- Lawfulness, fairness & transparency.
- Purpose limitation.
- Data minimisation.
- Storage limitation.
- Integrity and confidentiality.
We may collect, store and use the following kinds of personal information:
- information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation);
- information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters;
- Associates – can include personal information such as name, contact details, work history, education, skills, training, and other onboarding compliance requirements. We may use this information to provide work-seeking services, to assess your suitability to work as well as administrative and management purposes in connection with providing work seeking services;
- Administer payments to associates/suppliers;
- Data captured for surveys/delivery of services to clients;
- any other information that you choose to send to us.
Lawful basis for processing your data and what we do with the information we collect
We process your personal data for our legitimate business interests for operating our business and to fulfil contractual obligations with our clients. We may also process your data to comply with legal obligations we have with HMRC and other government bodies. For all other processing we will obtain your consent before using any of your personal data.
The information collected will be used for:
- send you general (non-marketing) commercial communications;
- administering the website including improve your browsing experience and enable your use of the services available on the website;
- send you email notifications which you have specifically requested;
- send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by email or similar technology where you have specifically agreed to this (you can inform us at any time if you no longer require marketing communications);
- deal with enquiries and complaints made by or about you relating to the website, and services or other correspondence;
- provide sourced consultancy and work opportunities services which includes holding information provided by associates including contact details, work history, skills and information required by HMRC for processing and retaining associates;
- where you submit personal information for publication on our website or other online media and publications, we will publish and otherwise use that information in accordance with the license or consent you grant to us;
- use the details submitted by you to complete a 360 assessment;
- use the details submitted by you to complete a personality preference assessment;
- use the details submitted by you on Survey Monkey at our request to complete an analytical project;
We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.
We may share limited information with other Capita Businesses for legitimate purposes as part of our necessary obligations for internal reporting, processing of invoices and payments and to update existing customers of service and product updates or opportunities available within Capita plc Group.
In addition, we may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling; and
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided in this privacy statement, we will not provide your information to third parties.
International Data Transfers
Information that we collect may be stored, processed and transferred between any of the countries in which we operate in or supply from to enable us to use the information in accordance with this privacy statement. International transfers outside of the EU, e.g. Capita India and the US will be managed under Privacy Shield agreed terms or via other adequate security assessments and data protection controls (including EU model clauses) to enable us to carry out our service obligations to our clients, suppliers and business partners.
All personal data stored and processed by us is securely stored within the European Union. There is no systematic transfer of data outside of the EU for any other purpose than outlined above.
Security of Your Personal Information and Retention
We continue to take all reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall- protected) servers.
Blue Sky retains your personal information for only as long as stipulated within our Data Retention Policy or where required in accordance with our client contractual retention period. Blue Sky does not seek to retain data for any longer than necessary to carry out our service and fulfil our statutory and contractual obligations. For further details on the retention periods of your personal data, please contact us using the details further below.
Third Party Websites
This privacy notice is strictly for the Blue Sky website and services only. Where this website contains links to other websites, users should review the privacy notices on those other websites on how their personal data is handled.
COOKIES AND WEB BEACONS
IMPORTANT INFORMATION – PLEASE READ!
Cookies are small text files which are planted by this website on your computer’s hard drive. They enable our sites to “remember” who you are.
Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
- Look at the use you make of certain features on the site like audio and video media files.
- Identify and track users that register, log into our sites and accept cookies.
- Look at site traffic to enable us to improve your experience and track interest of our products.
We may use web beacons in automated emails but not in conjunction with cookies.
Please see the table below for details of the cookies we use on our website (we recommend reading this on a desktop device).
|Persistent cookies are used by Google Analytics to track users’ movements through our site. Only anonymous information about you is collected.||Click here for an overview of privacy at Google.|
(Persistent and Session cookie)
|This cookie determines the use of our website. It tracks clicks, cursor movement and scrolling on the page. All information is anonymous.||Click here for an overview of privacy at HotJar.|
|This cookie is used by Facebook to deliver a series of advertisement products.||Click here for an overview of privacy at Facebook.|
|This cookie is used by LinkedIn to track the use of embedded services and track visitors on multiple websites in order to present relevant advertisement based on the visitor.||Click here for an overview of privacy at LinkedIn.|
|This cookie enables us to identify the source of your registration for marketing purposes, track email campaigns and website movements.||Click here for an overview of privacy at CommuniGator.|
|Google Tag Manager
|ads/ga-audience||This cookie is used by Google AdWords to re-engage visitors that are likely to convert into customers based on their online behaviour across the website.||Click here for an overview of privacy at Google.|
There are a number of ways to give us your consent:
- You can use appropriate browser settings.
- You can use third party tools to control Flash and Google Analytics’ cookies.
HOW TO TURN COOKIES ON AND OFF USING BROWSER SETTINGS
Most browsers are automatically set to accept cookies but if you are using Microsoft’s Internet Explorer, Mozilla Firefox, Apple’s Safari or Google Chrome, you should be able to configure your browser to restrict cookies or block all cookies if you wish. If you disable cookies you should still be able to login and use any secure areas of our sites. However, you may find you need to re-enter your user details.
Adjusting cookie settings on a web browser is not very easy at the moment, but the Government has promised that browser manufacturers will be making these settings more user-friendly so that they comply with new laws which came into force in May 2011. In the meantime, more information about cookies, including some browser-specific instructions on how to restrict or block cookies, may be found on the IAB’s website at www.youronlinechoices.com/uk. As at 1 July 2015, the relevant page for adjusting your browser settings is at www.youronlinechoices.com/uk/five-top-tips.
HOW TO TURN COOKIES ON AND OFF USING THIRD PARTY TOOLS
- We use Flash cookies with our media files. You can see and remove those by going to Adobe’s site at: macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
- We also use Google Analytics which uses analytic cookies in combination with certain code. You can stop being tracked by Google Analytics across all websites by going to Google’s site at: google.com/dlpage/gaoptout
We’ll tell you about new ways to indicate your consent to cookies as they become available.
Here’s some more information about the different types of cookies we use.
If you watch a video file or listen to an audio file on our website, you will be using Adobe Flash. This will store another type of cookie on your computer called a Local Shared Object or Flash cookie. It allows us to count the total number of times each file is played; how many people watch videos right to the end and how many people give up half way through. You can’t use your normal browser to remove Flash cookies, but Adobe’s website explains how to do that. Our videos are embedded via Vimeo and YouTube which all have their own privacy and cookie policies.
We use session cookies to identify and track users who enter any registered areas of our site. Session cookies are deleted when you close your browser. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from your computer. Typically, they will store information in the form of a session identification that does not personally identify you.
When users visit our website and set choices or preferences, persistent cookies may be used to remembers these options. They provide convenient and rapid access to familiar objects, which enhances your user experience. Persistent cookies are stored as text files on the hard drive of a computer and usually have expiration dates of one or two years. Some persistent cookies on our site are built to construct company and individual profiles.
Also, called a web bug or a pixel tag or a clear GIF. A web beacon is an often-transparent graphic image, usually no larger than 1 pixel × 1 pixel, which is placed on a web site and/or in an HTML email that is used to monitor your behaviour when you visit our site or receive an HTML email from us.
You cannot opt out of or refuse web beacons. However, where they are used in conjunction with cookies you can stop them by opting out of cookies – see the IAB website at www.youronlinechoices.com/uk
Blue Sky recognises the further rights of data subjects under the GDPR which include;
- The right to be informed – we will only process your data in accordance with this privacy notice or whereby we obtain explicit consent from you;
- The right of access (or otherwise known as subject access request) – you have the right to obtain a copy of your personal data that we hold. Please contact us with a description of the exact information you are seeking using the information below;
- The right to rectification – if any of your personal data is incorrect or has changed, please contact us and we will correct it;
- The right to erasure (or the right to be forgotten) – your right to have your information deleted or no longer used for processing unless there is a legal or other reason for continuing to process it. Please contact us if you have any queries or requests;
- The right to restrict processing or object to processing – you have the right to restrict or stop us processing your information any further, but will not affect any processing which has taken place. If you no longer wish your data to be processed or used, please contact us;
- The right to data portability – you have the right to request a copy of your data in a machine-readable format for any personal data provided by you;
- Rights related to automated decision making and profiling – you have the right not to be subject to a decision when it is based on automatic processing and it produces a legal effect or a similarly significant effect on the individual;
- The right to withdraw consent – where we are processing your data using your consent, you may withdraw this consent at any time by writing to us using the information below;
- The right to complain to the Supervisory Authority – if you are unhappy with our response, you have the right to complain to the Supervisory Authority, the details of which are below:
Supervisory Authority: Information Commissioner’s Office (ICO)
How to contact us
If you wish to contact us to make a Subject access request, request rectification, object to processing or have any other queries relating to this website, your personal data or have a complaint, please contact us using the information below:
Blue Sky Performance Improvement
The Old Malt House
33 The Street
Or use our contact page at https://blue-sky.co.uk/contact-us/
The data controller responsible in respect of the information collected on this website is Blue Sky. Blue Sky is registered under Information Commissions Office – Reg. no. Z6674638
We may update this privacy statement from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.
We may also notify you of changes to our privacy statement by email.