Privacy Notice: Data Protection Complaints
9-2-3 Jobs Limited (“9-2-3” or “we”) considers the privacy and security of your personal information to be very important. We are committed to protecting your privacy; we’ll only process your personal data where it is fair to do so, and to the extent that it is necessary for us to carry out our lawful business activities. If you would like to discuss this further, or have any questions, please don’t hesitate to contact us using the contact details set out at the bottom of this privacy notice.
In Annex 1 to this Privacy Notice, we explain what we mean by “personal data”, “processing”, “data protection complaints”, “special category personal data” and other terms used in the notice.
What personal data do we process?
The personal data we process may include your name, email address, telephone number, any personal data or special category personal data which you mention when submitting your data protection complaint to us and any personal data or special category personal data which we already hold on our electronic systems but have been processing for a different purpose - for example, because you have been a candidate / client / business contact of 9-2-3.
From where do we source this personal data?
The personal data which we process in investigating and remedying your data protection complaint is obtained:
From you. We may obtain your personal data and/or special category personal data from the statements which you make when submitting your data protection complaint to us, from telephone calls and other conversations between you and our employees and/or contractors, and/or from emails which you send to us;
From our existing electronic systems. It is possible that we may already have been processing some of your personal data or special category personal data on our electronic systems for a different purpose - for example, because you have been a candidate / client / business contact of 9-2-3. If you make a data protection complaint, then in order to fully investigate your complaint and take any appropriate remedial action, we may need to process this personal or special category personal data.
For what purposes will we process your personal data?
To investigate / remedy the matters set out in your data protection complaint. We will use the personal data and/or special category personal data you supply as part of your data protection complaint, and potentially other personal data and/or special category personal data which we already hold about you on our electronic systems, to investigate the matters raised in your data protection complaint and to take any such remedial action as we consider appropriate.
Processing for regulatory/legal reasons. In rare cases, we may also be required to disclose your personal data to the Information Commissioner, and may also use your personal data for the purpose of establishing, bringing or defending any legal or regulatory claims.
Who is the data controller in respect of the personal data processed by 9-2-3?
9-2-3 is the ‘data controller’ of this information; we decide what your personal information is used for, and the ways in which it is processed. Our contact details are set out at the bottom of this privacy notice.
On what legal basis does 9-2-3 process my personal data?
The legal bases on which 9-2-3 processes your personal data is:
1.That of our legal obligation to take appropriate steps to respond to your data protection complaint, including making enquiries into the subject matter of the complaint (Data (Use and Access) Act 2025, s.164(4) and (5)); and
2. That of our legitimate interest in using your personal data for the purpose of establishing, bringing or defending any legal claims.
However, if we need to process any of your special category personal data which is submitted as part of your data protection complaint form, or which we already hold on our electronic systems and which we need to process in order to investigate / remedy your complaint, we will also rely on the basis that such processing is necessary for a “Substantial Public Interest” reason - that is, it is necessary in order to comply with a regulatory requirement to handle data protection complaints.
If your data protection complaint progresses to legal action, we will at that stage need to rely on a different basis for processing any special category personal data - processing which is necessary for the establishment, exercise or defence of legal claims.
What is our legitimate interest in processing this personal data?
We have a legitimate interest in processing any data necessary to bring, establish or defend any legal claims as necessary from time to time.
We will only use your personal data for our legitimate interests in circumstances where we have established that those legitimate interests are not overridden by your rights and freedoms.
For how long will we retain your personal data?
We will keep records of your data protection complaint, our investigations into it, and any action taken, for 2 years after the date of the final resolution of your data protection complaint. Please note that if we have already held your personal data or special category personal data on our electronic systems prior to the submission of your data protection complaint, that personal data / special category personal data will be retained in accordance with our policies on the processing of candidate, client or business contact personal data, as applicable. Please click here for more details of these policies: https://www.923jobs.com/privacypolicy.
With whom will your personal data be shared?
Your personal data may be shared with:
Law enforcement or regulatory bodies or agencies or courts. If we receive a request from a regulatory or law enforcement body or agency, and if permitted by UK data protection laws, we may disclose certain personal information to such bodies or agencies. In the event of a legal claim, we may also need to disclose certain personal information to the court;
New business owners. If at any point in the future, 9-2-3 were to merge with or be acquired by another business or company, we may share your personal information with the new owners of the business or company and their advisors;
Third party suppliers of services to 9-2-3. These may include but are not limited to:
Software, database and cloud storage suppliers, including companies trading as Zoho, Google and Microsoft;
IT support providers; and
Professional advisors including but not limited to lawyers and accountants.
We require minimum standards of confidentiality and data protection from these third party suppliers. It is possible that the personal information which we collect may be transferred to and stored and processed in countries outside the UK where our third party service providers have operations, including the EEA and the United States. Where this is required by law, any international transfers of your personal information will be made pursuant to appropriate safeguards.
What happens if you visit our website?
Please note that if you visit our website, www.923jobs.com, then we will collect and process additional personal data relating to you. For further details, including information about what personal data we collect from visitors to our website and the purposes for which we process it, please see our web visitors’ privacy notice (https://www.923jobs.com/privacy).
What rights do you have in relation to this processing of your personal data?
Your data protection rights include:
The right to be informed about the collection and use of your personal data;
The right of access to your personal data and the right to request a copy of the information we hold about you and supplementary details about it;
The right to have corrected any inaccuracies in the personal data we hold about you, including the right to update or add to the information we hold about you if you consider that it is incomplete;
The right to have personal data blocked, erased or destroyed in certain circumstances. For example, you might seek to exercise this right if we no longer needed to process your personal data for the purposes for which it was provided. This right is not absolute and we may not always be able to comply with your request, but please be assured that we will consider your request and our legal obligations in relation to it very seriously. More information about your right to have your personal data erased can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/;
The right to object to, or to restrict, the processing of personal data under certain circumstances. For example, you might seek to exercise this right if any of the information we hold about you is inaccurate. This right is not absolute and we may not always be able to comply with your request, but please be assured that we will consider your request and our legal obligations in relation to it very seriously. More information about your right to object to our processing of your personal data can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-object/;
The right to object to the use of your personal data for direct marketing purposes; if you let us know that you object to this use of your personal data, then we will of course stop using it for this purpose immediately. You can exercise this right using the contact details set out below, but each direct marketing communication which we send to you will also contain a link to enable you to stop receiving our newsletters;
The right to receive any information we hold about you in a machine-readable, structured, and commonly-used format. You can also ask us to send this information directly to a third party organisation if you would prefer to do so. This right only applies in certain circumstances; for example, it will only apply to personal data which we process where we have clearly requested, and you have given, your consent for this processing;
The right to withdraw consent. Where we have requested your consent to carry out any processing of your data, and you have given us this consent, you can of course withdraw your consent at any time;
The right to complain to 9-2-3. If you have a concern about the way 9-2-3 has processed your personal data, then in the first instance you may wish to make a complaint directly to us. The information set out at https://www.923jobs.com/privacypolicy about how you can do this may assist you;
The right to complain to the Information Commissioner’s Office (the “ICO”). If you have a concern about the way 9-2-3 has processed your personal data, you are also entitled to lodge a complaint with a supervisory authority. In the UK, the supervisory authority is the ICO, which can be contacted at: https://ico.org.uk/concerns/.
Further information about these rights generally is available at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
We’re sure that you will understand that we may require evidence of your identity before we are able to act on any request made in relation to the above rights.
Who should you contact if you wish to exercise your rights in relation to, or for further information about, this processing of your personal data?
If you would like to proceed in exercising these rights, or for further information about our processing of your personal data, please contact Helen Wright on 07789 270183 or helen@923jobs.com.
Updates to the 9-2-3 privacy policy
This privacy policy may be changed by 9-2-3 at any time. If from time to time we make any changes to this privacy notice which will affect our processing of your personal data, we will notify you by email.
9-2-3 Jobs Limited
07789 270183/helen@923jobs.com
Annex 1: Meaning of Terms used in the Privacy Notice
“Personal data” is information relating to you, and from which you may be identified, which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device.
A “Data Protection Complaint” is a complaint which is submitted by you to 9-2-3 using the form set out on the Data Protection page of www.923jobs.com, and which relates to the way in which you believe 9-2-3 has processed your personal data or special category personal data.
"Processing" means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.
“Special category personal data” means personal data revealing or concerning an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership, genetic and biometric data.