Data Protection Complaints

KICKWISE LTD ("Kickwise", "we", "us" or "our") is committed to handling personal information lawfully, fairly, transparently and securely.

This procedure explains how you can raise a concern or complaint about the way we collect, use, disclose, store, retain, secure or otherwise process personal information. It also explains what you can expect from us after we receive a data protection complaint.

This procedure applies to individuals whose personal information is processed by KICKWISE LTD, including candidates, football players, employers, recruitment clients, prospective clients, users of our services, members of our Candidate Pool, job applicants, contractors, freelancers and other individuals who interact with us.

You do not need to refer to data protection legislation, identify a particular legal provision or use any specific legal terminology for us to treat your communication as a data protection complaint.

You may contact us if you are concerned about the way we have handled personal information about you, or about another person where you are authorised to act on their behalf.

A data protection complaint may relate to, for example:

• how we collected or used personal information;

• the lawful basis or purpose for which information was processed;

• who has been able to access or receive personal information;

• the handling of a CV, candidate profile, job application, account or recruitment record;

• information that you believe is inaccurate, incomplete or out of date;

• information being retained for longer than necessary;

• the security of personal information;

• an actual or suspected unauthorised disclosure, access, loss, alteration or destruction of personal information;

• the way we handled a request to exercise a data protection right; or

• any other concern about our processing of personal information.

If you are unsure whether your concern is a data protection complaint, you may still contact us. We will review the matter and determine how it should be handled.

The easiest way to submit a data protection complaint is by email:

privacy@kickwise.co.uk

You may also write to us at:

KICKWISE LTD
71–75 Shelton Street
Covent Garden
London WC2H 9JQ
United Kingdom

To help us understand and investigate your complaint efficiently, please provide as much relevant information as you reasonably can. This may include:

• your name and preferred contact details;

• the email address associated with your Kickwise account, where applicable;

• a clear description of your concern;

• relevant dates, communications, job applications or recruitment references;

• details of the outcome you are seeking, if any; and

• any supporting information that may assist our investigation.

Please do not send more personal information than is reasonably necessary for us to understand your complaint.

If your complaint contains confidential or sensitive information, we recommend that you contact us using a private communication channel rather than posting the information publicly or sending it through social media.

You may submit a complaint on behalf of another individual.

Where appropriate, we may ask for reasonable evidence that you are authorised to act on that person's behalf before we disclose information, discuss their personal data with you or take action that could affect their rights.

We will only request identity or authority information where it is necessary and proportionate to protect the individual concerned and the security of their personal information.

We aim to acknowledge data protection complaints as soon as reasonably practicable.

In all cases, we will acknowledge receipt of a data protection complaint within 30 days of receiving it, in accordance with applicable UK data protection law.

Our acknowledgement may confirm that we have received the complaint, identify the person or team handling it, request further information where necessary, provide a reference number where appropriate and explain what you can expect next.

The 30-day acknowledgement period is not a waiting period. We will begin taking appropriate steps to consider and investigate a complaint without undue delay after it is received.

We will take appropriate steps to investigate data protection complaints fairly, objectively and without undue delay.

Depending on the nature of the complaint, our investigation may include:

• reviewing the information you have provided;

• checking relevant account, profile, application, recruitment or communication records;

• reviewing access permissions, system records or security information where relevant;

• considering the privacy information, procedures and controls that applied at the relevant time;

• speaking with relevant members of our team;

• obtaining information or assistance from a service provider or processor where necessary; and

• asking you for additional information where we cannot reasonably investigate the matter without it.

We will limit access to complaint information to people who reasonably need it for the purpose of investigating, managing or reviewing the complaint.

Where a complaint remains under investigation, we will keep you appropriately informed about its progress.

The nature and frequency of updates will depend on the circumstances and complexity of the matter. If we require further information from you, or if the investigation takes longer than initially expected, we will explain this where appropriate.

We will not allow the 30-day acknowledgement period to delay the investigation of your complaint.

Once we have completed our investigation, we will communicate the outcome to you without unjustifiable or excessive delay.

Where appropriate, our response will explain:

• the issues we considered;

• the outcome of our investigation;

• any relevant findings;

• any action we have taken or intend to take; and

• any further steps available to you if you remain dissatisfied.

Where we identify an error, weakness or compliance issue, we will consider appropriate corrective measures. These may include correcting or deleting information, restricting access, changing permissions or procedures, improving security controls, updating privacy information, providing internal guidance or taking other proportionate remedial action.

Where we conclude that our handling of personal information was appropriate, we will explain the basis for that conclusion sufficiently for you to understand our response.

A data protection complaint is distinct from a request to exercise a data protection right.

Depending on the circumstances, applicable law may give you rights in relation to your personal information, including rights of access, correction, erasure, restriction, objection and data portability.

If the same communication contains both a complaint and a request to exercise a data protection right, we will identify and handle each element under the requirements that apply to it. The complaints process will not be used to delay the handling of a valid rights request.

For more information about how we process personal information and the rights that may be available to you, please refer to our Privacy Policy.

If your complaint indicates that personal information may have been accidentally or unlawfully lost, destroyed, altered, disclosed, accessed or made unavailable, we will also assess the matter under our personal data breach procedures.

Where required, we will take any additional action required by applicable data protection law, including considering whether notification to the Information Commissioner's Office or affected individuals is necessary.

We encourage you to contact us first so that we have an opportunity to investigate and respond to your concern.

However, you also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK's independent data protection regulator. Contacting us first does not prevent you from contacting the ICO or exercising any other rights available to you.

Information about making a complaint to the ICO is available at:

https://ico.org.uk/make-a-complaint/

We will process information provided in connection with a complaint where necessary to receive, investigate, manage and respond to the complaint, to protect our services and users, to establish or defend legal rights where appropriate, and to comply with our legal and regulatory obligations.

We may retain appropriate records of complaints, correspondence, investigations, decisions and corrective actions in accordance with our data retention requirements and applicable law.

Complaint records will be protected using appropriate technical and organisational measures and will not be used for unrelated purposes unless there is an appropriate lawful basis for doing so.

Further information about how KICKWISE LTD processes personal information is available in our Privacy Policy.

We want our complaints process to be reasonably accessible.

If you require reasonable assistance to make a complaint or to communicate with us about a complaint, please contact us at privacy@kickwise.co.uk and explain the support you require. We will consider reasonable adjustments in accordance with applicable law.

We may update this procedure from time to time to reflect changes in law, regulatory guidance, our services, our systems or the way we process personal information.

Where we make material changes, we will publish the updated version through our legal pages and update the applicable version information.

For questions, concerns or complaints about the way KICKWISE LTD handles personal information, please contact:

KICKWISE LTD
Email: privacy@kickwise.co.uk
Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom
ICO Registration Number: ZC237974