Privacy Policy
OdnetAfrica Ltd Privacy Policy
Last Updated: 21.01.2025
1. Introduction
Welcome to OdnetAfrica Ltd. We’re a multi-faceted consultancy specialising in media, tourism, and human resources services. We’re committed to protecting the privacy and security of the personal data we collect, use, and store. This Privacy Policy outlines how we handle your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This policy applies to everyone who interacts with us, including website visitors, prospective clients, existing clients, job applicants, media contacts, and other business partners.
2. Our Commitment to Your Privacy
At OdnetAfrica Ltd, your privacy is paramount. We adhere to these principles:
* Transparency: We’ll be clear about how and why we collect and use your personal data.
* Purpose Limitation: We’ll only collect data for specified, explicit, and legitimate purposes.
* Data Minimisation: We’ll only collect data that’s adequate, relevant, and limited to what’s necessary for our purposes.
* Accuracy: We’ll keep your personal data accurate and up-to-date.
* Storage Limitation: We won’t keep your personal data longer than necessary.
* Integrity & Confidentiality: We’ll process your personal data securely, ensuring its protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage.
* Accountability: We’ll be able to demonstrate compliance with these principles.
3. Information We Collect
We may collect and process various types of personal data, depending on your interaction with us:
a. Information You Provide to Us Directly:
This includes data you submit through our website forms, email correspondence, phone calls, during consultations, or through application processes. This may include:
* Contact Information: Name, email address, phone number, postal address.
* Professional Information: Company name, job title, industry, professional background, CVs, cover letters, employment history, qualifications (for HR consultancy services).
* Financial Information: Payment details (for services rendered), billing addresses.
* Enquiry Details: Information related to your media, tourism, or HR consultancy needs.
* Feedback: Survey responses, testimonials, comments.
b. Information We Collect Automatically (Website Usage):
When you visit our website, we may automatically collect:
* Technical Data: IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
* Usage Data: Information about how you use our website, products, and services, including pages visited, links clicked, and duration of visits.
* Cookie Data: Information collected through cookies and similar tracking technologies (please refer to our separate Cookie Policy for more details).
c. Information We Receive from Third Parties:
We may receive personal data about you from third parties, such as:
* Referral Partners: If you’re referred to us by a business partner.
* Publicly Available Sources: Professional networking sites, company websites, public registers.
* Service Providers: Analytics providers, payment processors, background check providers (with your consent, for HR services).
d. Special Category Data:
In very limited circumstances, and only when necessary for specific HR consultancy services (e.g., diversity and inclusion initiatives, or health-related accommodations for job applications), we may collect “special category” data (e.g., data revealing racial or ethnic origin, health data). We’ll only do this with your explicit consent or where strictly necessary and permissible under UK GDPR.
4. How We Use Your Information (Purposes and Legal Basis)
We’ll only use your personal data when the law allows us to. Most commonly, we’ll use your personal data in the following circumstances:
| Purpose of Processing | Legal Basis for Processing |
|—|—|
| To provide our consultancy services | Performance of a contract with you or to take steps at your request before entering into a contract. |
| To respond to your enquiries and requests | Legitimate interests (to respond effectively to customer service requests and grow our business). |
| To manage our client relationships | Performance of a contract with you; Legitimate interests (to keep our records updated, to provide quality service). |
| To process payments and billing | Performance of a contract with you; Compliance with a legal obligation (e.g., tax laws). |
| For internal record keeping and administration | Legitimate interests (for administration and to fulfil our legal obligations effectively). |
| To improve our website, products, and services | Legitimate interests (to keep our website updated and relevant, to develop our business). |
| For marketing and promotional communications | Consent (where required); Legitimate interests (to develop our products/services and grow our business, only where you haven’t opted out and we believe you’d be genuinely interested). You can opt out at any time. |
| To comply with legal and regulatory obligations | Compliance with a legal obligation (e.g., tax, fraud prevention, regulatory reporting). |
| For recruitment purposes (HR Consultancy) | Performance of a contract (e.g., for job applicants); Legitimate interests (to assess suitability for roles); Consent (for special category data or specific background checks); Compliance with legal obligations (e.g., right to work checks). |
| For dispute resolution and legal claims | Legitimate interests (to protect our business, enforce our legal rights, and defend against claims); Compliance with a legal obligation. |
5. Confidentiality and Engagement Terms (Beyond Contracts)
While we strive to define the scope of our work, specific deliverables, and key terms in our Client Engagement Agreements and, where applicable, Non-Disclosure Agreements (NDAs), this Privacy Policy serves as a foundational layer of our commitment to confidentiality and data protection.
* Complementary to Contracts: This Privacy Policy acts as a comprehensive statement of our practices regarding all personal data. Issues of confidentiality, data security, and data handling that may not be intricately detailed within specific clauses of an NDA or an individual client contract are nonetheless covered by the overarching principles and obligations outlined within this Privacy Policy and our internal data protection framework.
* Duty of Confidentiality: Beyond contractual obligations, we maintain a common law and ethical duty of confidentiality regarding all sensitive client information and personal data entrusted to us, adhering to the highest professional standards in the media, tourism, and HR consultancy sectors.
* Data Handled by Policy: Even if a formal NDA isn’t in place for a specific preliminary discussion or if certain data isn’t explicitly listed as “confidential” in a contract, any personal data shared with us, or information generated through our engagement, will be handled with the utmost discretion and in accordance with the security and confidentiality provisions of this Privacy Policy and UK data protection law.
* Third-Party Involvement: We expect any third parties involved in, or gaining knowledge of, our client engagements to respect the privacy and confidentiality standards set forth in this policy and any specific contractual agreements. Unauthorized disclosure or misuse of information, including personal data, by a third party, particularly for defamatory purposes, is taken extremely seriously and may result in legal action, as outlined in our Terms of Service and applicable laws.
6. Our Role as HR Consultants
It’s important to clarify our role within the Human Resources consultancy section of our services, as highlighted on our website:
* As consultants, the jobs and opportunities we assist our clients in securing for their candidates are not offered by us. We act as facilitators and advisors.
* Consequently, the parameters, requirements, and ultimate terms & conditions of engagement and contracting for any employment opportunity are not within our control. This includes, but isn’t limited to, control over recruitment timelines, specific contractual terms, or the ultimate decision regarding employment.
* Crucially, OdnetAfrica Ltd does NOT offer, supply, or help acquire sponsorship in any capacity for work, such as a Certificate of Sponsorship (COS). Our services are purely consultative, helping clients navigate their HR needs and connect with suitable talent within the established legal frameworks. We do not engage in activities that would fall under immigration sponsorship.
7. How We Share Your Information
We’ll only share your personal data with third parties when it’s necessary for providing our services, fulfilling a legal obligation, or with your explicit consent. This may include:
* Service Providers: Third-party companies that provide services on our behalf, such as IT support, payment processing, website hosting, or analytics. We ensure these providers are contractually obligated to protect your data and comply with UK GDPR.
* Professional Advisers: Lawyers, accountants, auditors, and insurers who provide professional services to us.
* Clients/Job Applicants (for HR Consultancy): If you’re a job applicant, we’ll share your relevant professional information (e.g., CV) with prospective employers (our clients) with your consent. If you’re a client seeking talent, we’ll share candidate data with you as part of the recruitment process.
* Regulatory & Law Enforcement Bodies: Where required by law, court order, or governmental request.
* Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity.
We do not sell your personal data to third parties.
8. International Transfers
We primarily store and process your personal data within the UK and the European Economic Area (EEA). However, some of our service providers may operate outside these regions. Whenever we transfer your personal data outside the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of these safeguards is implemented:
* We’ll only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
* Where we use certain service providers, we may use specific contracts approved by the UK government or the European Commission which give personal data the same protection it has in the UK/EEA (e.g., Standard Contractual Clauses).
9. Data Security
We’ve implemented robust security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. These measures include:
* Technical Safeguards: Encryption, firewalls, secure servers, regular penetration testing.
* Organisational Safeguards: Strict access controls, staff training on data protection, clear internal policies and procedures.
* Physical Safeguards: Secure office environments.
Despite our efforts, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
10. Data Retention
We’ll only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider 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.
For example:
* Client Data: Typically retained for the duration of the client relationship plus a period to meet legal obligations (e.g., 6-7 years for tax and accounting records).
* Job Applicant Data: Typically retained for 6 months to 1 year after a role is filled unless you consent to a longer retention period for future opportunities.
* Marketing Data: Retained until you unsubscribe or request removal.
11. Your Legal Rights (Data Subject Rights)
Under UK GDPR, you have these rights concerning your personal data:
* The right to be informed: About how we collect and use your personal data (this Privacy Policy).
* The right of access: To request a copy of the personal data we hold about you (a “Subject Access Request”).
* The right to rectification: To request that inaccurate or incomplete personal data we hold about you is corrected.
* The right to erasure (“the right to be forgotten”): To request that we delete or remove your personal data where there’s no compelling reason for its continued processing.
* The right to restrict processing: To request that we suspend the processing of your personal data in certain circumstances.
* The right to data portability: To request that we transfer your personal data to another organisation or to you directly, in a structured, commonly used, machine-readable format.
* The right to object: To our processing of your personal data where we’re relying on a legitimate interest, or for direct marketing purposes.
* Rights in relation to automated decision-making and profiling: To object to decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
To exercise any of these rights, please contact us at admin@odnetafrica.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data isn’t disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one calendar month.
12. Links to Other Websites
Our website may contain links to other websites of interest. However, once you’ve used these links to leave our site, you should note that we don’t have any control over that other website. Therefore, we can’t be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites aren’t governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any changes we make will be posted on this page with an updated “Last Updated” date. We encourage you to review this Privacy Policy periodically to stay informed about how we’re protecting your information.
14. Contact Us
If you have any questions about this Privacy Policy or our data protection practices, please contact our Data Protection Lead:
Email: admin@odnetafrica.com
15. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Their website is www.ico.org.uk. We’d appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.