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APS Intelligence

Privacy Policy

1. Who we are

APS Intelligence Ltd, registered in England and Wales with company number 06666674 provides collaborative solutions for the changing world of work. We use a collaborative system that employs psychological expertise and corporate experiences to solve intractable people problems and create thriving workplaces.

This notice describes the information (or ‘personal data’) which we collect about you, what we do with it and why, and how we protect it. It also describes your rights and how to exercise them.

2. Our role in data processing

In most situations, APS Intelligence acts as the data controller, deciding how and why we collect and use personal data (for example, in relation to our colleagues, recruitment, suppliers, marketing, and website). When we deliver services to clients, such as coaching, workshops, or assessments, we may instead act as a data processor. In these cases, we only process personal data on the client's documented instructions, under the terms of our contract with them.

3. Personal data you provide to us

When you contract with us. We collect your business contact details to record contracted deliverables of our products. We do this because it is in our legitimate interest to collect this information in order to create and maintain a relationship with you and your company. Information is kept for the duration of the contract we hold with your company, and we keep contract details as long as necessary to fulfil our legal obligations.

When we deliver our services. When delivering our services such as workshops, 1-2-1 coaching and executive coaching, we may receive and store personal data that you provide to us. For example, when you participate in our workshops, we may collect information such as competency self-assessments, skills, training, and awareness opinions. This data is generally anonymised to protect your privacy unless you are explicitly advised otherwise.

We collect and process this information based on our legitimate interests and contractual obligations, provided that your interests and fundamental rights do not override those interests. In some cases, we will only process your personal data with your explicit consent, which we will request in writing before the activity begins. You may withdraw your consent at any time. For example, if we collect sensitive data relating to your mental health and wellbeing, we will only do so with your prior consent.

If, during the course of our work, you disclose sensitive or private information to an APS Intelligence colleague which suggests a potential safeguarding concern, we have a duty of care to report this to the relevant person (see Section 7).

When you apply for a job with us. When you apply for a position with us, we collect personal information, including your name, contact details, career history, education, and other relevant details you choose to provide. This information is used solely for evaluating your suitability for the role. As part of our recruitment process, we may engage third-party service providers to assist with this assessment.

For successful candidates, we carry out pre-employment checks, including verifying references, confirming the right to work, ID checks, and a basic DBS check. We also review publicly available social media profiles and conduct a Google search as part of these checks to ensure alignment with our values and ethics. This reflects our commitment to maintaining a professional workplace and safeguarding the integrity of our brand. These reviews are conducted in a fair and proportionate manner, focusing only on publicly available, relevant information.

Your data is securely stored and retained for up to six months after the last interaction, unless you provide written consent for extended retention or further retention is legally required.

When you interact with us on social media. We use Instagram, TikTok, LinkedIn and BlueSky to raise awareness of our brand, promote our activities and events and contact potential customers. When you comment on our posts or send us a private message, you may provide us with your personal data. We will use the personal data you provide us to communicate with you and for no other purpose. We may also obtain information from Instagram, TikTok and LinkedIn about how you interact and engage with our posts and pages on their platform. We process your personal data on the basis our legitimate interest in promoting our business, increasing audience engagement on social media, and responding to your comments and queries. We are not responsible for the privacy practices of social media platforms. If you wish to obtain more information about how LinkedIn, Instagram and TikTok collect and manage your personal data, please visit the privacy notices on their websites.

When you provide services to us. If you or your company provides services to us, we may collect information about you in the course of our business dealings, including the names and contact details of key stakeholders, information collected during the course of any due diligence we conduct – noting that this information may include data collected from third parties – and information relating to our business relationship. We collect this personal data on the basis that we have a legitimate interest in doing business with you and will retain it only for as long as is necessary for the duration of our business relationship and any subsequent audit period.

We will notify you if we process any personal information for any other purpose than the ones listed above.

4. Personal data we collect automatically from you

When you visit our website, we collect internet or other electronic network activity information through the use of cookies and other trackers. Depending on your tracking preferences, the information we collect may include technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.

This information is collected via cookies for more detailed information regarding cookies, please visit our Cookie Notice at https://www.apsintel.com/cookie-policy

5. How we store your information

We store your personal data for different time periods depending on the category of personal data and the nature of relationship that you have with us. We determine how long we need personal data on a case-by-case basis, but our goal is to keep your personal data for the shortest period possible to achieve the purpose for which personal data is collected.

We consider the following criteria when we are making decisions on how long we will retain your personal data:

  • The category of personal data.
  • Whether personal data is typically deleted based on specific schedules, such as website information.
  • Whether personal data is necessary to operate or provide our services. For example, account information may be retained for a longer period based on the Agreement you have with us.
  • How long we need to retain the personal data to comply with our legal obligations.

6. How we protect your data

We take appropriate technical, organisational, and administrative security measures to protect your information. In implementing these measures, we choose those which are proportionate and appropriate for the sensitivity of the information being processed. These measures are taken in line with the European General Data Protection Regulation 2016 and the UK Data Protection Act 2018.

7. Processing in emergency situations (threat to life, vital interests)

In extreme situations where an imminent threat to life or serious harm exists, APS Intelligence Ltd may process personal data under the UK GDPR's provisions for protecting vital interests. This may occur where it is necessary to protect the life of the data subject or another individual, and where consent cannot reasonably be obtained. This processing is done under Article 6(1)(d) of the UK GDPR.

If this involves special category data, such as health or wellbeing information you have provided to us, processing may also be carried out under Article 9(2)(c) of the UK GDPR where it is necessary to protect vital interests and the individual cannot give consent.

Such situations are rare and would only occur in emergencies, for example to inform emergency services or appropriate contacts where serious harm is suspected.

8. International Data Transfers

APS Intelligence may transfer personal data from the EEA or the UK to other countries, including personal data we receive from individuals residing in the EEA or the UK who visit our websites and/or who may use our services or otherwise interact with us. Please note that the term personal data used in this Notice is equivalent to the term “personal data” under applicable European and UK data protection laws for individuals located in the EEA or the UK.

When we do transfer data outside the we will make sure suitable safeguards are in place for these transfers. These may include the EU’s Standard Contractual Clauses (“SCCs”) and the UK Information Commissioner’s Office’s International Data Transfer Addendum (“IDTA”), as applicable, supplemented by additional security measures as recommended by the European Data Protection Board.

9. Your Data Protection Rights

You have the right to request a copy of all the information we hold about you and to ask us to correct any inaccurate personal information concerning you. We may in some circumstances need to check that what you have told us is accurate and require a form of identification.

We will respect your rights to:

  • Access your information.
  • Ask us to delete your information.
  • Stop or restrict us from processing your information.
  • Seek rectification, correction or updates to your information.
  • Withdraw your consent at any time (to the extent we base processing on consent)
  • Remain free from discrimination for exercising your rights as described above.

We will always endeavour to fulfil your requests. However, we may not be able to do so immediately if we have a lawful reason or a legal or contractual obligation to retain the information or continue the processing. We will notify you if this is the case.

To exercise any of these rights, please contact us using the details below.

APS Intelligence Limited
Leytonstone House
High Road Leytonstone
London
E11 1GA
email: data@apsintel.com
telephone: 020 3950 1108

APS Intelligence Ltd. is registered with UK Information Commissioner’s Office (ICO), the supervisory authority that handles data protection law in the UK, with reference Z1889683.

You have the right to make a complaint to the ICO. You can contact them at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
email: casework@ico.org.uk
telephone: 0303 123 1113

10. Annual review cycle

The Audit and Risk Committee reviews this policy annually. Review dates and version history are recorded in the APS Intelligence Document Register to provide a full audit trail.