Red Snapper Group

Privacy

1st August 2025

We respect your privacy and are committed to protecting your personal information. This Privacy Notice explains how we collect, use, and protect your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Information We Collect:

We collect and process the following personal data:

Information you provide to us:

– Any personal identifiers provided by you (e.g. name, email address, phone number)

– Communication preferences

Information automatically collected:

– Device information (IP address, browser type, operating system)

– Cookies and similar technologies

Call Recording

Calls to and from our organisation are recorded for the following purposes:

Quality assurance: To monitor and improve the standard of our customer service;

Staff training: To provide training opportunities and professional development for our team members;

Dispute resolution: To maintain accurate records that may be referenced in the event of any disputes or complaints;

Legal compliance: To ensure we meet our regulatory and legal obligations.

These recordings are stored securely and are only accessed by authorised personnel. We retain call recordings in accordance with our data retention policy and applicable legal requirements.

The lawful bases for our recording of calls are:

Legitimate interests under Article 6(1)(f) UK GDPR, for us to ensure accuracy of information, support staff training and quality assurance and to defend against legal claims.

Legal obligation (Article 6(1)(c)), and where appropriate Performance of a Contract (Article 6(1)(b).

Lawful Basis for Processing:

We process your personal data under the following lawful bases:

– Contract: Processing necessary for performing our contract with you.

– Legal Obligation: Compliance with UK law.

– Legitimate Interests: Where processing is necessary for our legitimate business interests.

– Consent: Where you have given specific consent for processing.

How We Use Your Information:

We use your information to:

– Provide our services

– Communicate with you about our services

– Improve our website and user experience

– Protect against fraud

– Meet our legal obligations

Data Retention:

We retain your personal data only for as long as necessary for the purposes for which it was collected, including legal, accounting and reporting requirements.

Information Sharing:

We may share your information with:

– Service providers who assist in our operations.

– Professional advisers (solicitors, bankers, auditors).

– Government bodies when required by law.

– Third parties in the event of a business transfer.

All third-party processors are bound by data processing agreements that ensure UK GDPR compliance.

International Transfers:

If we transfer your data outside the UK, we ensure appropriate safeguards are in place, such as:

– UK International Data Transfer Agreements.

– Standard Contractual Clauses including International Data Transfer Addendums.

– UK Adequacy Regulations.

– Binding Corporate Rules.

Individual Rights:

In certain circumstances you have the right to:

– Access your personal data;

– Rectify inaccurate data;

– Erase your data (‘right to be forgotten’);

– Restrict processing;

– Data portability;

– Object to processing;

– Withdraw consent.

Data Controller(s):

Data Controller: Red Snapper Group Ltd and its subsidiary companies:

  • Red Snapper Recruitment Limited
  • Red Snapper Learning Ltd
  • Red Snapper Media Limited
  • Red Snapper Managed Services Limited

Associate company:

  • 999 Learning Limited

Contact Details:

Telephone: 020 3119 3300

For privacy-related queries or to exercise your rights, contact our Data Protection Officer:

Email: DPO@redsnappergroup.co.uk

You have the right to lodge a complaint with the Information Commissioner’s Office:

ICO Helpline: 0303 123 1113

Rights of Individuals

Current data protection legislation provides individuals, or data subjects, with a number of rights providing them with control around the collection and processing of their personal data by organisations.  You may exercise any of these Rights at any time, and may do so free of charge.

In order to authorise Red Snapper Group Ltd. to conduct a subject access request you must provide your contact details, verification of your identity to a satisfactory level, and the reason for the request.

In the majority of cases we will respond in full to your request in 30 days as standard. If we are unable to satisfy this within such time frames, we will inform you of the nature of the delay and ensure it is fulfilled within a total of 60 days from the date the request was originally made.

You can make a request against any of the following rights to Red Snapper Group Ltd.’s Data Protection Officer by contacting them in writing at dpo@redsnappergroup.co.uk.

Right of Access

You have the right to know who (has received your data); what (data categories we hold on you); where (this data is processed); why (purpose of processing); and when (how long we retain the data for). Such information will also include any international data transfers, the identities of any third party processors, and how we received your data in the first instance.

Right to Rectification

If you believe we hold incorrect data on you, you have the right for it to be corrected. If data is found to be objectively incorrect, it will be rectified. Any subjective basis for challenging the accuracy of data cannot be corrected in the same way, but you do have the right to present your opinion and for that to be interlinked with the data in dispute.

Right to Erasure

You have a right to be forgotten. If the data we hold on you is no longer needed for the purpose for which it was collected, and there is no lawful reason for us to continue processing it, it will be deleted by us through our operating procedures. You do however also have the right to request this erasure yourself.

Right to Data Portability

As the owner of your personal data, you maintain the right to request a copy of the data you provided us be returned to you at any time. This can be provided to you or directly to a new data controller should you require. Personal data will be provided to you in a structured, commonly used, and machine-readable format.

Right to Object

We process data according to a number of legal bases, you have the right to request and challenge these.

If we are processing your data on the basis of the consent you have provided to us for the use of your data, you are free to inform us of your withdrawal of this consent at any time.

If we are processing your data on the basis of Red Snapper Group Ltd.’s legitimate interests, you can object to such processing; unless a legitimate and irrefutable reason (e.g. legal obligation) for the processing can then be provided that supersedes your rights as the data subject, such processing must stop.

Lodging a Complaint

If you do not believe your personal data has been processed legally, or that we have not satisfied the criteria of any of your rights as a data subject, you have the right to lodge a formal complaint. In the first instance you should inform Red Snapper’s Data Protection Officer of the issue(s) by contacting them on dpo@redsnappergroup.co.uk.

Should you find that you are still dissatisfied after Red Snapper’s DPO has provided you with a resolution we deem complete, then you are entitled to escalate the complaint to the Information Commissioner’s Office (the supervisory authority). The ICO is an independent body responsible for ensuring that organisations comply with current data protection legislation.

You should complain to the ICO if you believe we have failed to respond to your request; refused your request; failed to provide the information requested; or not responded within the designated time frame of 30 days.

You may lodge a complaint with the ICO here: https://ico.org.uk/concerns/handling/