Summary

This is Sentinel Consultants Limited’s privacy statement. It details how Sentinel Consultants, subsidiaries, branches or representative offices, websites, services, and any third-party providers collect, use, secure, transfer, and share your information.

The company’s address is

Sentinel Consultants Limited

19 Ballanard Road,

Douglas,

Isle of Man,

IM2 5HA

The company’s Data Protection Registration number is R004063

Classes of data collected and processed

As a company, we mainly provide due diligence and enhanced due diligence on User’s customers. As a result, we primarily collect and process data concerning the following data subjects;

  1. Customers & Suppliers of Sentinel Consultants (Users data)
  2. Data belonging to Users Customers
  3. Data belonging to Employees and prospective Employees/Applicants

The type and amount of collected data differ concerning these three “data subjects” groups.

Users/Suppliers Users Customers Employees/Applicants
Full name Full name Full name
Address Gender Address
Contact numbers Date of birth Nationality
Company status Nationality Date of birth
Email addresses Address Previous address
Industry Previous addresses Email address
Payment history with Sentinel Consultants Credit/Debit card number Contact numbers
Anonymised system usage activity Contact numbers Employment History
IP address Passport Passport number
Browser Driving licence Driving licence number
Operating system National insurance number Bank details
Search terms Nationality Salary details
Referring URLs Visa number if applicable Credit history
Analytics on how the services are used National Health service number Health information
Functional system cookies Electricity (MPAN) number  
Anonymised tracking cookies Bank details  
Business credit history Company Directorships  
Regulatory history Property title information  

How we collect this data?

Users/Suppliers Users Customers Employees/Applicants
From the user through the website From the user through the website From the individual through the website
During conversations over the phone Company Registries During conversations over the phone
Email Local Government Email
Post Credit reference agencies Post
Company Registries Data suppliers Data Suppliers
Data Suppliers Open source information Credit reference agencies
Credit reference agencies   Recruitment agencies
Relevant regulators Job Centre
  Training providers
  Health Professionals

In addition, we may also gather information only about Users from our key accounts where there is a contractual relationship for us to supply our goods and services to their members/users. At this point, they become our Users. The user supplies consent to the critical account for this transfer.

Why do we collect this data?

The reasons we collect information is different depending on the types of “data subject”

Users/Suppliers Users Customers Employees/Applicants
Assess the suitability of the service Compliance with user’s regulatory obligations in respect of; Assess the suitability of the applicant
To enable the smooth operation of the service Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 To administer the employee/employer relationship
Administer and manage the account Proceeds of Crime Act 2002 Pay salary
Collect payments and manage billing Financial Sanctions legislation as part of the Policing and Crime Act Due diligence
Prevent fraud and financial crime 4th Money Laundering Directive Manage effective communications
Manage communications Users request/authority Ensure contractual obligations are met
Ensure contractual obligations are met Due diligence Compliance & regulatory obligations
Compliance with regulatory obligations   Absentee due to sickness
System auditing  
System optimisation  
Communicate system notifications  
Communicate features and upgrades  
Communicate other products and services offered within the system and by the company  
Due diligence  

Lawful basis of processing

The lawful basis of processing is based on the “data subject” as detailed below:

Users/Suppliers Users Customers Employees/Applicants
Consent – We will process your data to tell you about our services and improve the service we give to you. Legal Obligation – Data is processed in order that the User can comply with their regulatory obligations. Consent – We may process your data to tell you about any opportunities that may be of interest to you.
Contract – We will process your data to perform the necessary actions to deliver our commitment under the contract we have with you. Contract – Data is processed so that the User can fulfil the obligations under the contract they have with the customer. Contract – We will process your data to perform necessary actions to deliver our commitment under the contract we have with you.
Legal Obligation – We will process your data to comply with our regulatory obligations. Legitimate Interest – We may process the data to defend a legal claim made against us. Legal Obligation – We will process your data to comply with our regulatory obligations.
Legitimate Interest – We may process your data for market research, analysis of system performance and statistical analysis   Special Category – We may process health data if you are absent due to sickness or injury.
Legitimate Interest – We may process your data to defend a legal claim made against us. Legitimate Interest – We may process your data for market research, analysis of system performance and statistical analysis, or to defend a legal claim made against us.
Legitimate Interest – We may process your data to keep you informed you about upgrades to the system. We may also contact you about complimentary goods and services we as a company supply that we think may be of benefit to you.

Data Sharing

Sentinel Consultants Limited will only share User data and Employee/Applicant data with its partners and agents to fulfil its obligations under the contract it has with them and satisfy the Legal Obligation requirement.

Sentinel Consultants Limited will only share users’ customer data with its partners to carry out the various checks and screens required under the users’ legal obligation and fulfil contractual obligations.

Sentinel Consultants may share data with prospective/future employers, government bodies, local and central authorities, third-party companies offering employee benefits, financial institutions, and, if necessary, legal representatives.

Nothing in this document will prevent Sentinel Consultants from disclosing data as required by law or by any competent authority.

Sentinel Consultants Limited does not share data for any reason other than what is stated above.

In respect of data that is shared as above, Sentinel Consultants Limited contractually requires all service providers and/or recipients to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements.

Sentinel Consultants reserves the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts on the acquirer’s part to protect/use the information consistent with this statement.

How long do we keep information?

In respect of Users/Supplier data:

We only keep information for the time necessary to fulfil the contractual obligation.

We will keep information about our legal obligation for an extended period, but we will only keep the information required for this purpose.

In respect of Employee data:

We only keep the information for the time necessary to fulfil the contractual obligation.

We will keep information for an extended period of time related to our Legal Obligation, but we will only keep the necessary information for this purpose.

We will keep data for an extended period so that we can provide any necessary references that the data subject requests.

This data will not be processed for any other reason beyond the term of employment.

In respect of User Customer data:

We will keep User Customer data for as long as the User deems necessary under the terms of their privacy policy and data retention requirements under the legal basis of processing between them and their customers. Sentinel Consultants provides all the tools and features within the system to enable Users to manage their data obligations as required.

International Transfers

Sentinel Consultants does not carry out transfers of data outside the EEA.

Data Subject Rights

The following outlines the rights you hold regarding processing your data by Sentinel Consultants.

Some of the rights may not apply or have limitations based on the legal basis of the processing that is taking place.

Right to be informed

All Data Subjects will be informed that Sentinel Consultants is processing their data and the legal basis under which that data is being processed.

The users are responsible for informing their customers of the data processing, reasons, and rights resulting from that data being with Sentinel Consultants.

Right of Access & Correction

All Users have the right to access all of the data Sentinel Consultants are processing about them. All data processed by Sentinel Consultants is held within the User’s account on the system. As a result, all users can correct any incorrect information held about them by using this facility.

Right to Erasure (Right to be Forgotten)

All Data Subjects have the right to be forgotten regarding any data collected and processed on the Consent basis. If you would like to exercise this right, please contact us so we can ensure your requirements are met.

Right to restrict processing

All Data Subjects have the right to restrict Sentinel Consultants’ processing of their data to limit the activities it can carry out in relation to the Consent Basis of processing.

If you would like to exercise this right, please contact us so we can ensure your requirements are met.

Right to Object (Right to withhold Consent)

All Data Subjects have the Right to Object or withhold consent to processing their data under the Consent basis of processing as detailed in the “Lawful basis of processing” table above.

If you would like to exercise this right, please get in touch with us so we can ensure your requirements are met.

Rights relating to Users, Customer data

The rights relating to data held by Sentinel Consultants about User’s Customer data may differ from those stated above. However, the User should detail and enforce those rights by their agreement between them and their customer.

Sentinel Consultants cannot dictate or enforce those rights on the User. However, Sentinel Consultants will provide any practicable assistance to enable the User to fulfil their obligations under that agreement and any legal obligation.

How we protect Personal Data

The security of personal data is extremely important to Sentinel Consultants. As a company, we are committed to protecting the information we collect, store, and process. We maintain administrative, technical, and physical safeguards designed to protect the data you provide or we collect against accidental, unlawful, or unauthorised destruction, loss, alteration, access, disclosure, or use.

We use TLS encryption in transit and AES encryption at rest on our system, from which we transfer and receive personal data.

Sentinel Consultants stores data only for as long as necessary to fulfil the purpose for which it is collected unless otherwise required or authorised by applicable law.

Sentinel Consultants takes appropriate measures to destroy or permanently de-identify any data instructed to remove from the system as required by the User or legal authority.

Use of Cookies

We use cookies to control some of the site’s activities, such as your credentials and the storage of collective processes as you carry out activities within the site. This type of activity is essential when using our site. Anyone preventing these types of Cookies will be unable to use the system.

Cookies are also sometimes used to improve a visitor’s website experience. We may sometimes use cookies on this website to record aggregate statistical information about visitors to our site and the use that our visitors make of the website. When collected, this information is used by us to improve our website and further enhance the visitor experience and may be shared with advertisers. Please note that no personally identifiable information is recorded.

We may also use the cookies to gather information about your general internet use to further assist us in developing our website.  Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on your computer’s hard drive. Cookies contain information transferred to your computer’s hard drive, stored there, and moved to us where appropriate to help us improve our website and service.

All computers can decline cookies.  You can quickly decline or remove cookies from your computer using the settings within the Internet Options section in your computer control panel. Please note that declining essential system cookies will render the site unusable.

Our third-party suppliers may also use cookies on their websites. We have no control over this, and you should review the privacy policy of any third-party supplier you visit due to a link on this website.

Updates to this statement

This statement may be updated from time to time in light of regulatory changes or changes in how Sentinel Consultants operates regarding its data. We suggest you review this statement regularly. We will notify you if any changes are significant and ensure your ongoing consent and/or acceptance.

Feedback or Questions relating to this statement

For any enquiries relating to this statement, Sentinel Consultants can be contacted in the following ways:

Address

Mr Andy Gray, Data Protection Officer
Sentinel Consultants Limited
19 Ballanard Road,

Douglas,

Isle of Man,

IM2 5HA

Telephone +44xxxxxx

Email Info@sentinel-cdd.com

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