1. Purpose 

This privacy policy describes how Avella collects and uses personal information about you in accordance with the applicable data protection legislation.

Avella recognises the importance of this data and the risks related to its possession of such data. Avella is committed to protecting the privacy and security of your personal information.

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Avella is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy policy.

This policy sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this policy at any time.

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It is important that you read this policy, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 

2. About Avella

Avella Security Limited is a cyber security consultancy providing advisory, assurance, security architecture, and related cyber security services to clients in the private and public sectors.

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In the course of delivering our services and operating our business, we may collect and process personal information relating to clients, prospective clients, suppliers, business contacts, website users, and other individuals with whom we interact.

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We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have any questions about this privacy policy or how we handle your personal information, please contact the Data Protection Officer, contact details of whom are set out in Section 3.0. You have the right to make a complaint at any time for data protection and privacy issues.

3. Data Protection Officer 
Daryl Flack Avella Security Ltd., 80 Strand, London, WC2R 0RL, 0845 86 22 365 
Regulator: Information Commissioner's Office.

If you have any questions about this privacy policy or how we handle your personal information, please contact the Data Protection Officer at Daryl.flack@avella-security.com

4. Data Protection Principles 

Avella has committed to applying the highest standards of data protection in accordance with applicable data protection regulations. This means that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

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5. The Information We Hold 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, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

• Gender

• Job Title 

6. How is Your Personal Information Collected? 
 We collect personal information in a number of ways, including:

-        when you contact us directly by email, telephone, through our website, or through other communications;

-        when you or your organisation engage us to provide services;

-        during the course of delivering our services to clients;

-        when you subscribe to updates, request information, attend meetings or events, or otherwise interact with us in a business context;

-        from third parties who introduce you or your organisation to us, where lawful to do so; and

-        through normal use of our website, including through cookies and similar technologies where applicable.

7. How We Will Use Information About You

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

• Where we need to perform the contract, we have entered into with you.

• Where we need to comply with a legal obligation.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else's interests).

• Where it is needed in the public interest [or for official purposes].

Specifically, we may use your personal information to:

• communicate with you and respond to enquiries;

• establish, manage, and maintain client, supplier, and business relationships;

• provide consultancy, assurance, security architecture, managed or support services;

• manage projects, engagements, contracts, and service delivery;

• administer our business operations, including governance, finance, procurement, audit, risk management, and internal reporting;

• comply with legal, regulatory, and contractual obligations;

• manage complaints, requests, and the exercise of legal or data protection rights;

• improve our services, website, communications, and business operations; and

• where lawful, provide you with information about our services and related updates.

8. Situations in Which We Will Use Your Personal Information 

We will only use your personal information where we have a lawful basis to do so under applicable data protection law. Most commonly, this will be because:

• the processing is necessary for the performance of a contract with you or your organisation;

• the processing is necessary to comply with a legal or regulatory obligation;

• the processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests; or

• you have given your consent, where consent is the appropriate lawful basis.

In some cases, more than one lawful basis may apply to the same processing activity.

The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information. 

9. If You Fail to Provide Personal Information 
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you (such as delivering an ethical phish), or we may be prevented from complying with our legal obligations.. 

10. Change of Purpose 

We will only use your personal information for the purposes for which we collected it, unless we 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. How We Use Sensitive Personal Information 

"Special categories" sensitive personal information requires higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.

• Where we need to carry out our legal obligations.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about you during legitimate business activities with the appropriate safeguards.

12. Do We Need Your Consent? 

We do not need your consent if we use your personal information to comply with a legal obligation or exercise specific rights under the law.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

13. Information About Criminal Convictions 

We may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you cannot give your consent, or where you have already made the information public.

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We may also process such information about you during legitimate business activities with the appropriate safeguards.

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14. Data Sharing 

We may have to share your data with third parties, including third-party service providers and other entities in the business. We require third parties to respect the security of your data and to treat it in accordance with the law.

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. This may involve us sharing your information with: 

• Third party service providers who help us operate our business; 

• Organisations that introduce you to us;

• Companies that we introduce you to; and

• Companies you ask us to share your data with

If the make-up of Avella changes or such changes are proposed we may share your data with third parties to allow us to sell, merge or transfer aspects of our business or acquire or merge into other businesses. We will only do this if they agree to keep your data to the same standards, we have set for holding your data. Following such a change other parties may use your data in line with these standards.

"Third parties" includes third-party service providers (including contractors and designated agents) that have a requirement to process your data for specific purposes. The third parties and systems that may process personal information on our behalf include, where relevant:

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1 - Microsoft Office 365 

2 - ClickUp

3 - CHARLIE HR

4 - Xero

5 - Website hosting and support providers

6 - Other specialist service providers, professional advisers, or subcontractors where necessary to operate our business or deliver services, and where appropriate contractual and security measures are in place

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All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

15. Data Security 

We have implemented appropriate technical and organisational measures to protect personal information against unauthorised or unlawful processing, accidental loss, destruction, or damage.

Access to personal information is limited to those employees, contractors, and service providers who have a legitimate business need to know and who are subject to appropriate confidentiality and security obligations.

We also maintain procedures for identifying, investigating, and responding to personal data incidents and breaches, and we will notify affected individuals and regulators where we are legally required to do so.

16. Data Retention 

We will retain personal information only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, contractual, accounting, and reporting requirements, and in accordance with our records retention requirements.

Retention periods for your personal information are decided by considering 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. This will vary depending upon the relationship we have with you but in general terms for:

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 - Business relationships we will retain your information for seven (7) years after the end of our relationship;

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Personal information attributed to prospective clients that do not onboard with Avella is kept for no longer than is necessary. This will vary depending on circumstances but in general terms this will be a minimum of six (6) months.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

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If you have any questions regarding data retention, please speak to the Data Protection Officer.

17. Cookies 

A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself. A cookie cannot read data from your hard disk or read cookie files created by other sites. Cookies, however, enhance our web site performance in several ways, including providing a secure way for us to verify your identity during your visit to our web site and personalising your experience on our site, making it more convenient for you.

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Our web site uses cookies so that we can serve you better. The site uses visitor tracking software that will use cookies to track information about how visitors come to the website, which pages they visit, and other actions that visitors make whilst on the site. This data is then used to improve the user experience of the web site. All user data collected in this manner is anonymous.

18. Data Subject Access Request, Correction, Erasure, and Restriction 

Your duty to inform us of changes.

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

Your rights in connection with personal information.

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

No fee is usually required.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it

19. Right to Withdraw Consent In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

20. Changes to this Policy Statement 

We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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