Last Updated: 12/06/2019
Compass respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
This Privacy Notice only applies to personal information that we collect through our Compass social media channels (“Social Media”) and is applicable to data subjects in Europe only (although similar rights may apply in some countries outside of Europe). For personal information that we collect when you use or interact with our services, please see our Contacts Privacy Notice.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
3. What does Compass do?
Food is our core competence. We pride ourselves on our ability to provide clients with a wide range of innovative dining solutions. We have a passion for great food and great service. We create inspiring dining solutions that deliver the full benefit of outsourced food services, combining our global strength with passionate local teams. We operate at thousands of client locations around the world, from hospitals, schools and oil rigs to corporate headquarters and the world’s biggest entertainment venues. Where appropriate, we can also support our clients beyond food with a range of soft services – consistently delivered to a high standard, cost effectively.
For more information about Compass Group, please see the “What We Do” section of our Website.
4. What personal information does Compass collect and why?
By visiting and interacting with Compass Social Media, Compass may collect personal information about you. We may use this information and other information we hold about you (for example collected through our Social Media or your employment with us if you are an employee);
o to establish or improve business relations
o assess job applications
o to send you communications we believe may be of interest to you (where we have your consent to do so)
o to help us improve our Social Media pages and your experience of using them, for administration purposes and for legal compliance.
Compass may also monitor comments and questions and other postings you make on Social Media so we can respond to them. We may also monitor postings to protect employees and others against illegal activities or behaviour by users of these pages which could be damaging or distressing to others and to protect Compass's reputation and confidential information.
If you are an employee or consultant of Compass's, we may also monitor Social Media to verify that Compass's policies are complied with, including our IT use, Social Media use, data protection and security policies.
The personal information that we may collect about you broadly falls into the following categories:
o Information that you provide voluntarily
Certain parts of our Social Media may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
o Information that we collect automatically
When you visit our Social Media, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Social Media, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Social Media, where they come from, and what content on our Social Media is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Social Media to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology”.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.
5. Who does Compass share my personal information with?
We may disclose your personal information to the following categories of recipients:
o to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Social Media), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
o to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
o to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
o to any other person with your consent to the disclosure.
6. Legal basis for processing personal information (EEA visitors only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person e.g. in response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes).
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
7. Cookies and similar tracking technology
8. How does Compass keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
9. International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Social Media providers e.g. Linkedin may have servers that are located around the world. This means that when we collect your personal information it may be processed in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice. These include:
o imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to “international frameworks” that aim to ensure adequate protection; and
o Compass implementing a range of organisational and technical security measures, such as cyber security training, role based access and encryption, where appropriate, to ensure personal data is secure.
10. Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible then we will securely store your personal information and isolate it from any further processing until deletion is possible.
11. Your data protection rights
You have the following data protection rights:
o If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
o In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
o You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
o Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
o You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.)
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
12. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
13. How to contact us
If you have any questions or concerns about our use of your personal information, please contact us at firstname.lastname@example.org.
The data controller of your personal information is Compass Group PLC and its affiliates.