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We take your privacy seriously and will only use your personal information to administer your account and to provide the service you have requested from us. However from time to time we would like to contact you by email, post and phone. We’ll always treat your details with the utmost care and will never sell them to other companies.

Privacy Policy

Third Party Policy

Aspekt32 Ltd is committed to protecting and respecting your privacy. We have created this policy to inform you and make sure we are transparent about our processes. This policy might be subject to changes and updates. This version was last updated on 22 May 2018.

This Data Processing Notice applies to you if (1) you are a referee, (2) if you reside within the European Union and (3) if your personal data is processed on Aspekt32 Ltd’s CRM database and other internal systems.
When you give a reference, you trust us with your personal data. This Data Processing Notice is meant to help you understand what personal data we collect, why we collect it and what we do with it. Furthermore, it will briefly outline your rights as a data subject. This is important, and we hope you will take the time to read it carefully. Your new rights under GDPR will only apply once the GDPR comes into effect on 25 May 2018.

General Data Protection Regulation

In accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) that comes into effect on 25 May 2018, Aspekt32 Ltd is obliged to issue a Data Processing Notice if we store your personal data in our database.

The GDPR is a new regulation which replaces the Data Protection Directive 95/46. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organizations can legally operate.

This Data Processing Notice will outline:
1. Aspekt32 Ltd as a data controller
2. Which personal data Aspekt32 Ltd collects and how we collect it
3. Why we hold your data and legal basis
4. How long will we store your data?
5. What are your rights under GDPR
6. Automated decision making
7. Lodging a complaint
8. Changes to this Data Processing Notice
9. Contact details for GDPR and data queries


1. Aspekt32 Ltd as a data controller

Aspekt32 Ltd will be what is known as the ‘Controller’ of the personal data you provide to us.

All our entities act as Data Controllers as they jointly determine the purposes and means of the processing of your personal data.

Your personal data will be stored on our servers and specifically in our global CRM system, Invenias. Your data can, therefore, be accessed by our employees who are based in various international offices. Please note that all the Aspekt32 Ltd offices, are obliged to comply with GDPR when processing your personal data, provided you reside in the European Union. We may also share your reference with our clients who then will only see your name, job title, and contact details.
Furthermore, we may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements or to protect the rights, property or safety of Aspekt32 Ltd, our customers, or other parties.


2. Which personal data Aspekt32 Ltd collects and how we collect it

Aspekt32 Ltd will collect the following personal data:

⦁ Your full name
⦁ Your job title
⦁ Your email addresses
⦁ Your (mobile) telephone number

We will receive this information from our candidate who needs to provide us with references as part of Aspekt32 Ltd’s compliance policy. We will then contact you to provide us with a reference. We will always confirm how we received your personal data.


3. Why we hold your data and legal basis

⦁ Aspekt32 Ltd will collect your personal data for the following purposes:
⦁ Contacting you in order to provide a reference for our candidate who nominated you as one of his/her referees;
⦁ Showing proof to our clients that we have asked for references; when requested by our clients.

The legal basis under the current laws for collecting and processing your personal data is legitimate interests. As we are a recruitment company our clients expect us to do background checks and to that end, we need to save some of your personal data to show that we have collected these references. We will need your input to screen the candidate and check his/her suitability for the job. Please note that the type of personal data we collect from you is limited to the data as set out in section 3. We may use your data if you would become a potential client of Aspekt32 Ltd in which case the Data Processing Notice to Clients and Supplier representatives applies.



4. How long will we store your data

Your personal data will be stored in our systems for the duration of the assignment of the candidate and for six years thereafter (and will be deleted thereafter) unless Aspekt32 Ltd needs to use this information for the defence of legal claim, or unless there is a direct statutory requirement under which Aspekt32 Ltd is obliged to keep your data stored in our internal database for a longer period of time.


5. What are your rights under GDPR

Under GDPR you are entitled to various rights:

• You can 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.
• You can 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). This means should you wish to be removed from Aspekt32 Ltd’s database, please email info@aspekt32.com. We will review and process your request within 30 days.
• You can object to the 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 particular 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. This means we will only send you marketing communication if you have opted in. You can opt out at any time by clicking the ‘unsubscribe’ link in the footer of the email in question and will be removed from the Aspekt32 Ltd marketing mailing list. You can also use the Aspekt32 Ltd Preference Centre to opt in and out of other communication from Aspekt32 Ltd.
• You can 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.
• You can request the transfer of your personal information to another party in certain formats, if practicable.
All such requests need to be addressed to info@aspekt32.com.

The fact that you can lodge a request does not necessarily mean we will grant your request at all times, especially if Aspekt32 Ltd has legitimate interest that outweighs your interests as an individual.

Aspekt32 Ltd will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, Aspekt32 Ltd may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (in the UK this will be the ICO) or seeking a judicial remedy.


6. Automated decision-making, including profiling

Aspekt32 Ltd will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you, in particular, to analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. We will not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects you as a data subject.


7. Lodging a complaint

If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to contact us via info@aspekt32.com.


8. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate (if significantly amended), notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.






9. Contact details for GDPR and data queries

Questions, comments, and requests regarding this Data Processing Notice are welcome and should be addressed to:

Oliver Seidel
Data Protection Officer
16 Warner Street
EC1R 5HA London
Phone +49 (0)69 348 770 940


Last updated on 22 May 2018