Data Protection, Processing & Retention Policy

Apple A Day Supply Ltd are committed to protecting and respecting your privacy. Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, and our associated companies as defined in section 1159 of the Companies Act 2006 (our Group). This notice (together with our policies and contract) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Apple A Day Supply Ltd processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Data (Use and Access) Act 2025, as amended from time to time. These laws establish the framework governing the processing, protection and security of personal data in the United Kingdom.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time the data controller is Apple A Day Supply Ltd 21A, Paxcroft Farm, Hilperton, Wiltshire. BA14 6JB.

Our nominated representative OR Data Protection Officer is Ashley Salmon, Team Leader.

WHO WE ARE AND WHAT WE DO

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services training, outsourcing, consultancy. We collect the personal data of the following types of people to allow us to undertake our business:

• Prospective and placed candidates for permanent or temporary roles;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

INFORMATION YOU GIVE TO US OR WE COLLECT ABOUT YOU

This is information about you that you give us by filling in forms at www.appleadaysupply.co.uk or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register with us in person, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

INFORMATION WE COLLECT ABOUT YOU WHEN YOU VISIT OUR WEBSITE

With regard to each of your visits to our site we will automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions and operating system and platform.

Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

INFORMATION WE OBTAIN FROM OTHER SOURCES

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, and personal recommendations. In this case we will inform you, by sending you this privacy notice, within one calendar month of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with our partners at ANZUK and third parties, including our CRM provider and our Isimio app, which stores/transmits data. We require ANZUK and these third-party providers to implement appropriate security measures to protect personal data and comply with applicable data protection legislation. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

PURPOSES OF THE PROCESSING AND THE LEGAL BASIS FOR PROCESSING

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
• The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
• Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
• We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
• We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
• We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).

DATA PROTECTION PRINCIPLES

Apple A Day Supply Ltd will process personal data in accordance with the principles set out within the UK GDPR. Personal data shall be:

• processed lawfully, fairly and transparently;
• collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary;
• accurate and, where necessary, kept up to date;
• retained only for as long as necessary; and
• protected through appropriate technical and organisational security measures.

LAWFUL BASIS FOR PROCESSING

Personal data means data which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of, or is likely to come into possession of, Apple A Day Supply Ltd.

Data will only be processed in compliance with the following legal bases under Article 6 of the UK GDPR, as applicable:

• Legitimate interests;
• Legal obligation;
• Consent;
• Performance of a contract;
• Any other lawful basis permitted by applicable legislation.

Data will be reviewed on a regular basis and in accordance with documented retention periods to ensure that it is accurate, relevant and up to date.

OUR LEGITIMATE BUSINESS INTERESTS

Our legitimate interests in collecting and retaining your personal data are described below:

• As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
• In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
• To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

CONSENT

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time, and we will make withdrawing consent as straightforward as giving it.

OTHER USES WE WILL MAKE OF YOUR DATA

• Use of our website;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• if requested by APSCo as part of our Compliance+ audit;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Apple A Day Supply Ltd does not currently make decisions based solely on automated processing that produce legal or similarly significant effects on individuals. We may use systems to assist in identifying, searching or matching information, however a person will always be involved in the decision-making process.

If Apple A Day Supply Ltd introduces automated decision-making processes in the future, appropriate safeguards will be implemented, including the right to obtain human intervention, express a point of view and challenge a decision where required by law.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Further information about the cookies we use can be found in our Cookie Policy.

RESPONSIBILITIES AND SECURITY MEASURES

Employees are responsible for ensuring that any changes to old or inaccurate data that they become aware of are reported and corrected in a timely fashion. In addition, all employees should ensure that appropriate information security and confidentiality measures are in place at all times.

For example:

• Computer screens should not be left unattended by individuals who are accessing personal information;
• Passwords and access credentials should not be disclosed or shared;
• Personnel files and other personal data should be stored in a place in which any unauthorised attempts to access them will be noticed. They should not be removed from their usual place of storage without good reason and appropriate authorisation;
• Personnel files should always be locked away when not in use and when in use should not be left unattended;
• Care should be taken when sending personal data by post or electronically, including the use of secure methods such as encryption where appropriate;
• Destroying or disposing of personal data counts as processing. Therefore, care should be taken in the disposal of any personal data to ensure that it is securely destroyed in accordance with company procedures;
• Any actual or suspected personal data breach must be reported immediately to the designated data protection contact in the company;

Any actual or suspected personal data breach will be investigated promptly and managed in accordance with applicable data protection legislation and Information Commissioner's Office guidance.

DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE EEA

We will share your personal information with:

• Any member of our group both in the EEA and outside of the EEA
• Selected third parties including:
  • clients for the purpose of introducing candidates to them;
  • candidates for the purpose of arranging interviews and engagements;
  • clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
  • subcontractors including email marketing specialists, event organisers, payment and other financial service providers
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Apple A Day Supply or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (www.appleadaysupply.co.uk) and other agreements; or to protect the rights, property, or safety of An Apple A Day Supply, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• We will share your email with any settings you are placed in to enable the setting to send over planning and lesson information should they wish to. They do not have permission to contact you for any other reason and if they do, please do inform us immediately.

The lawful basis for the third-party processing will include:

Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;

• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil their legal obligations.

WHERE WE STORE AND PROCESS YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. Where personal data is transferred outside the UK or EEA, Apple A Day Supply Ltd will take appropriate measures to ensure that personal data continues to be protected in accordance with applicable data protection legislation. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

RETENTION OF YOUR DATA

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and other lawful purposes. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:

• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged;
• our recruitment expertise and knowledge of the industry by country, sector and job role.

We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Our current retention notice is available upon request.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: asalmonappleadaysupply.co.uk

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Individuals may raise concerns regarding the way in which their personal data has been processed. Apple A Day Supply Ltd operates a process for handling data protection complaints. We will acknowledge complaints within 30 days and investigate and respond without undue delay. Individuals will be advised of their right to complain to the Information Commissioner's Office where appropriate.

UK GDPR and data protection legislation provide you with the following rights to:

• 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 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.
• 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 in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

ACCESS TO INFORMATION

UK GDPR and the Data Protection Act 2018 give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

Data subjects are entitled to obtain access to their personal data on request under the UK GDPR. All requests to access data should be referred to Ashley Salmon, Team Leader at asalmonappleadaysupply.co.uk.

Where a request is granted, the information will be provided within one month of the date of the request, subject to any lawful extensions permitted under applicable data protection legislation.

When responding to Subject Access Requests, Apple A Day Supply Ltd will carry out reasonable and proportionate searches for the requested information.

Any requests for access to a reference given by a third party should be referred to Ashley Salmon and will be treated with appropriate care. This is because the person providing the reference also has rights under data protection legislation and their personal information may not be disclosed without a lawful basis.

Your right of access can be exercised in accordance with the relevant legislation.

CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

CONTACT

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Ashley Salmon, Team Leader: asalmonappleadaysupply.co.uk

Last updated 04/07/2026

© An Apple A Day Supply 04/07/2026 | Next review due 04/07/2027

© Apple A Day Supply July 2026
Data Protection, Processing and Retention Policy | Tel: 01225 30 20 11 Email: infoappleadaysupply.co.uk