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Strategic Resources European Recruitment Consultants Ltd. Registered Company Number SC107007 (‘the Company’)
Privacy and Data Protection Policy
Privacy and data protection
15 August 2018
The Company is committed to protecting the privacy of individuals and to provide information on how the data is collected and what it is used for.
The Company provides work finding services, contractor management services and outsourced payrolling on behalf of Clients and Hirers. We require personal data to provide these services.
The information conveyed to the Company will only be used for the purpose of these services or for legal and/or regulatory compliance.
The Company is the data controller for the information that provided to us unless we advise otherwise.
The information may be held in electronic or physical formats.
All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 2018 (DPA 2018) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.
The Company collects and processes both personal data and sensitive personal data. It is required to do so in order to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.
This policy sets out how the Company implements the Data Protection Laws.
In this policy the following terms have the following meanings:
‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;
‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;
‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller;
‘personal data’* means any information relating to an individual who can be identified, such as by a name, photo, image, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;
‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘profiling’ means any form of automated processing of personal dataconsisting of the use of personal datato evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable individual;
‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.
* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.
‘Supervisory authority’ means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authorityis the Information Commissioner’s Office (ICO).
All of these definitions are italicised throughout this policy to remind the reader that they are defined terms.
The Company processes personal data in relation to its own staff, work-seekers, individuals and Client or Hirer contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z4853226.
The Company shall hold personal data for the following purposes:
The Company, on successful placement of a work-seeker or a staff employee, may request additional information. The Company will only ask for information which will be used in legitimate business interests to ensure that the applicable assignment can be undertaken lawfully. This may include:
1. The data protection principles
The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:
2. Legal basis for processing
The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.
The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.
Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers, Clients, Hirers or intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support), the Company will establish that it has a legal reason for making the transfer.
Requests may processed be from the following third parties:
3. Privacy by design and by default
The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:
For further information please refer to the Company’s Information Security Policy which is available on request from the Managing Director.
4. The Company Website
The Company may collect and process the following data about the individual:
All information individuals provide to us, is stored on secure servers.
Rights of the Individual
The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally when requested to do so by the individual.
1. Privacy notices
Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data.
Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month. If the Company intends to disclose the personal data to a third party, then the privacy notice will be issued when the personal data is first disclosed (if not issued sooner).
Data will be collected and processed from sources including the following:
Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it carries out further processing.
2. Subject access requests
The individual is entitled to access their personal data on request from the data controller.
Where the individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.
If the Company has given the personal data to any third parties it will inform those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data.
If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.
If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
5. Restriction of processing
The individual or a data controller at the individual’s request,has the right to ask the Company to restrict its processing of an individual’s personal data where:
If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data unless this proves impossible or involves disproportionate or unreasonable effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
6. Data portability
The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and has the right to transmit those data to another data controller in circumstances where:
Where feasible, the Company will send the personal data to a named third party on the individual’s request.
7. Object to processing
The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.
The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
The individual has the right to object to their personal data for direct marketing.
8. Enforcement of rights
All requests regarding individual rights should be sent to the person whose details are listed in the Appendix.
The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision-making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity, legal and contractual requirements.
Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee for the administrative costs involved.
9. Automated decision making
The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:
The Company will not carry out any automated decision-making or profiling using the personal data of a child.
Reporting personal data breaches
All data breaches should be referred to the persons whose details are listed in the Appendix.
1. Personal data breaches where the Company is the data controller:
Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.
Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.
2. Personal data breaches where the Company is the data processor:
The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.
3. Communicating personal data breaches to individuals
Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall inform all affected individuals without undue delay.
The Company will not be required to inform individuals about thepersonal data breach where:
All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:
If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy.
Alternatively, you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/
The Company Data Controller is the Managing Director who shall be responsible for the management of the following:
1. The lawfulness of processing conditions for personal data are:
2. The lawfulness of processing conditions for sensitive personal data are:
Retention of Individuals Personal Data
Several laws require the Company to keep various data for different periods of time. The Company shall retain documentation relating to work finding services for a period of 2 years after registration as a work-seeker. Should there have been no contact with the individual in that period after registration, the records of the individual will be deleted from the Company system subject to the necessary relevant or regulatory requirements.
The Company will not hold Personal Data for longer than is deemed necessary for the purposes for which the data is processed.
Retention and Processing of Contractor Personal Data
Contractors are defined as:
Consultancy Staff - Individuals who provide services through a Limited Company
Agency Workers – Individuals who provide services through an Umbrella Company
PAYE Agency Workers – under a contract for services with the Company
The default standard retention period for HMRC records is 6 years plus the current financial year. Personal data (please see the Definition of Personal Data) of Contractors, Limited Companies and Umbrella Companies, shall be retained as per the HMRC default standard retention period.
Personal data will only be retained beyond the standard default HMRC retention period if the retention of personal data can be justified for statutory, regulatory, legal or security reasons or for their historic value.