Catapult’s Privacy Notice

At Catapult, we respect your privacy and are committed to protecting your personal data. This privacy notice tells you about how we look after your personal data when you visit our website or use our app or otherwise communicate with us and it tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Catapult collects and processes your personal data through your use of our website and app or otherwise when you communicate or interact with us.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Catapult Limited is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you need to get hold of us for any reason in connection with your personal data, please email us at [email protected].

We are: Catapult Limited of 26 Curtain Road, London, EC2A 3NY

We are registered with the Information Commissioner’s Office, number ZA142302

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns about data protection before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 09 April 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Required for all Catapult Workers

· Contact Data includes name, email, phone number, date of birth, postcode

· Identity Data includes proof of right to work documents, passport or identity documents

· Application Data includes personality survey, application video, relevant work and education history

· Profile Data includes photo, profile video, feedback and survey responses, worker rating data

· Registration Data includes gender, nationality, residential address, National Insurance number

· Payment Data includes bank account details, payroll records, tax status information

· Correspondence Data includes email correspondence, notes and recordings of telephone conversations and Contact Data

· Usage Data includes information about how you use our website and app

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

· Marketing Data includes your preferences in receiving marketing from us.

Optional for Catapult Workers

· Location Data: Our app may be set up to collect data about your location. You can turn off this functionality at any time by turning off the location services settings for the mobile application on your device. If you use these location services, you acknowledge that we and our licensee may use your Location Data to provide and improve location-based products and services. We may also use GPS technology or other technology to determine your current location.

· Extra Data sometimes required for certain jobs: place of birth, naturalisation, UK residence data, marital status, detailed educational and work history, references, details about your next of kin, security information.

· Special Category Data includes details about race or ethnicity, religious or philosophical beliefs, trade union membership, information about your health, information about your criminal convictions.

We do not require you to provide us with any sensitive personal data (such as information about your health or any criminal record) in order to use our website and app. However, certain jobs or roles that appear on our website and app may require this type of information. It is your choice whether or not you choose to apply for such a job or role and, where you do, we make it clear when you first apply that this information will be collected.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

For Catapult Clients

· Contact Data includes name, position, business, email, phone, business address, Linkedin profile

· Correspondence Data includes email correspondence notes and recordings of telephone conversations and Contact Data

· Profile Data includes feedback and survey responses, client rating data

· Financial Data includes information about your bank account and any payments to or from us.

· Usage Data includes information about how you use our website.

· Marketing Data includes your preferences in receiving marketing from us.

For our business associates and others that interact with us

· Contact Data includes name, position, business, email, phone, business address, Linkedin profile

· Correspondence Data includes email correspondence notes and recordings of telephone conversations and Contact Data

· Usage Data includes information about how you use our website.

· Marketing Data includes your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

· Direct interactions. We collect the majority of your data when you choose to give this to us on our app or on our website, by email, over the phone, in person or otherwise.

· Automated technologies or interactions.

o If you as a Worker, choose to take the personality test, we will collect personal data provided by the test but we will not use that solely to make any automatic decision about you or the appropriate roles for you.

o As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website or app may become inaccessible or not function properly. For more information about the cookies we use, and how to disable them, please see https://www.joincatapult.com/content/cookies-policy/

· Third parties or publicly available sources. We may receive:

o Technical Data about you from analytics providers such as Google with servers based outside (as governed by our Cookie Policy https://www.joincatapult.com/content/cookies-policy/

· Contact Data from publically available sources; and

· Confirmation of your Contact Data or Identity Data if you are a Worker from third party ID verification services or credit reference agencies; and

· If you are a Worker, information about your placement from our Client and if you are a Client, information about the placement from the Worker.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

· To provide the services to you in accordance with our website Terms of Use or other agreement that we have with you; or

· Where it is necessary for our legitimate interests (or those of a third party) and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you and to improve the service that we offer).

· Where we need to comply with a legal or regulatory obligation (e.g. to have evidence of who you are or if you have a right to work in the UK).

Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

In respect of your Sensitive Data, we will only collect this from you where we are required to do so because a particular job requires it. Where you do so, we will take this as a clear affirmative action signifying your agreement to the processing of your Sensitive Data. You may withdraw our right to process your Sensitive Data on your behalf at any time.

Marketing – Opting out

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

For Catapult Workers

We may use your Contact, Technical, Usage and Application Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which jobs or roles may be relevant for you.

You will receive marketing communications from us if you have requested information from us or created an account with us and, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

For Catapult Clients

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

For our business associates and others that interact with us

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

5. Disclosures of your personal data

We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

For Catapult Workers

· Other companies in our company group.

· Our clients (who are making available the role or position) and who will then become data controllers of your personal data and will be directly responsible to you for how they treat and look after your personal data. When you start a new role with our Client, they will provide you with their own privacy notice explaining this and if they do not, you should ask for it.

· Our service providers acting as processors who may have servers based in the US who provide IT support, IT backup, data storage, email management and system administration services.

· Analytics and advertising service providers which may have servers based in the US - for the purpose of analysing user behaviour & retargeting

· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

· If you are referred to us by a friend of yours, we will share with your friend, headline information about the status of your application with us (i.e. whether or not you have signed up, been accepted, worked or been paid) so that your friend can see their entitlement to any referral fee they might be entitled to.

For Catapult Clients

· Our workers where you wish us to share information with them.

· Our service providers acting as processors who may have servers based in the US who provide IT support, IT backup, data storage, email management and system administration services.

· Analytics and advertising service providers which may have servers based in the US - for the purpose of analysing user behaviour & retargeting

For our business associates and others that interact with us

· Our service providers acting as processors who may have servers based in the US who provide IT support, IT backup, data storage, email management and system administration services.

· Analytics and advertising service providers which may have servers based in the US - for the purpose of analysing user behaviour & retargeting

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

A number of our service providers processing your personal data on our behalf have servers based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that either:

· we have a specific contract with that processor in a form approved by the European Commission which ensures that service provider gives your personal data the same protection it has in Europe; or

· if the provider is based in the US, it is a member of the US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right in certain circumstances to:

Request access to your personal data (commonly known as a "data subject access request").	This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you.	This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data.	This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.	You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data.	This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party.	We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.