How to contact us
If you have any questions regarding your personal data and how we may use it, including any queries relating to this Policy, please contact us at [email protected] or writing to the “Data Protection Manager” at the office address noted above.
It is important that the personal data we hold about you is accurate and current. Please keep us (or if you are an employee of one of our clients, where appropriate) informed if your personal data changes.
Aspen's data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").
For the purpose of Data Protection Legislation:
Personal data and Basis for Collection
Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Where Aspen is acting as a data controller, Aspen may collect, use, store and transfer different kinds of personal data about you which Aspen has grouped together as follows:
Subject to where Aspen needs to verify your identity and you provide your express consent for Aspen to process such information, Aspen does not process any Special Category personal data (as defined by Data Protection Legislation) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor does Aspen collect any information about criminal convictions and offences.
If you fail to provide personal data
Where Aspen needs to collect personal data by law, or under the terms of a contract Aspen has with you (or our client whom Aspen acts for) and you fail to provide that data when requested, Aspen may not be able to perform the contract it has or is trying to enter. In this case, Aspen may have to cancel the Services but it will notify you (or where appropriate, its client) if this is the case at the time.
How is your personal data collected?
Aspen uses different methods to collect personal data from and about you including through:
How Aspen uses your personal data
Aspen will only use your personal data when the law allows us to, ie, if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
Where we act as the data controller for client contact information, we have set out below in the table a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Aspen if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you or the company that you are connected to as
a new client and verify your identity (where required)
|Performance of a contract|
|To process and deliver the Services including:
(a) Manage accounts, payments, fees and charges
(b) contacting you and corresponding about the Services
|Performance of a contract Necessary for our legitimate interests
|To respond to queries and enquiries||(a) Identity
|To undertake marketing to you||(a) Identity
Where we act as a data processor of personal data on behalf of our clients, we will process personal data in accordance with our clients’ instructions, or in order to comply with a legal or regulatory obligation.
How your personal data may be shared
Where we act as the data controller for client contact information, or where permitted by Aspen’s data controller clients, personal data processed by Aspen may be shared as follows:
Where we provide your personal data to Data Processors or Sub-Processors we will have in place a written agreement with each third party confirming on what basis the third party will handle your personal data and will ensure that there are sufficient safeguards and processes in place to protect your personal data. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and only process that personal data in accordance with our (or our client’s) instructions. The third parties that we may send your personal data to are either within the European Economic Area (“EEA”) or to third parties under suitable protection mechanisms as laid out in applicable Data Protection Legislation.
How Aspen stores personal data
We are part of a Group of companies with offices in locations in the UK, USA, France Germany, India and Australia.
From time to time we may transfer your personal data from within the EEA to our offices outside of the EEA, such as those listed above, or other countries where we have put in place adequate security measures to ensure your personal data will be handled in a way that matches applicable Data Protection Legislation, so that where your personal data is being transferred to one of our global companies it will be processed in line with our EEA-based companies, regardless of which country they are in (even if they are outside of the EEA).
Separate to the above, we may also transfer your personal data to countries outside of the EEA to other people or companies for one of the legal bases for processing your personal data as indicated above, or at the request of our data controller clients. Where we do so, we will take all steps to ensure that any country to which the personal data has been transferred has suitable protection mechanisms in place to protect personal data, including (if applicable) use of EU Model Clauses in any contract with that third party for steps to be taken to keep personal data secure.
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed and have an Information Security Policy in place to which we adhere to. 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.
Personal Data Retention
We will only retain personal data in accordance with our retention policy, which includes:
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
To exercise any of the above rights please email your request to: [email protected]
Where you exercise your right to erasure (and we do not have another legal basis to hold on to that personal data) or where information is deleted in accordance with Aspen’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period Aspen retains the data.
Where you exercise your right to request access to the information Aspen processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Aspen will try to respond to all legitimate access 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.
The Website is not intended for children and Aspen will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.
If you would like to make a complaint in relation to how Aspen may have stored, used or processed your personal data, 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). Aspen would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We would like to place cookies on your computer to help us make your use of our Website better. Cookies are small text files that are placed on your computer by websites that you visit. They 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. Just so you know, the main cookies on our Website are from Google Analytics tracking and there’s also a session cookie generated that is essential to the running of the Website but holds no personal data.
Most web browsers allow some control of most cookies through the browser settings.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Other tracking technologies: Some of our website pages utilize cookies and other tracking technologies. A cookie is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall personal data previously indicated by a website user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your details to gain access to certain parts of the website.
We may also analyse information that does not contain personal data for trends and statistics.
Remember the Risks Whenever You Use the Internet
Aspen is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. While Aspen does its best to protect your personal data, Aspen cannot guarantee the security of any information that you transmit to Aspen and you are solely responsible for maintaining the secrecy of any passwords or other account information.