25TH May 2018
who we are,
how and why we collect, store, use and share personal information,
your rights in relation to your personal information, and
how to contact us and supervisory authorities in the event that you have a complaint.
Who we are ?
Sarah Harvey Limited ('we' or 'us') collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
The personal information we collect and use may include:
1) Personal information you provide to us
We collect the following personal information that you provide to us:
Previous employment / CV
2) Personal information you provide about third parties
If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:
shall consent on their behalf to the processing of their personal data;
shall receive any data protection notices on their behalf; and
shall consent on their behalf to the transfer of their personal data abroad.
How we use your personal information ?
We may process personal data concerning you in our manual and computerised/automated filing systems internally and, so far as is reasonably necessary, externally, for the purposes of complying with statutory requirements, meeting the our legitimate interests, properly conducting the our business, complying with the terms of your employment and for all purposes in connection with your employment with us.
Who your information may be shared with ?
We may share your information with:
Any third party providing services to us for the benefit of its employees;
HM Revenue and Customs or other authorities;
Prospective purchasers of all or any part of our business in return for suitable confidentiality undertakings regardless of the country to which the data is to be transferred;
Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
Government bodies for the purposes of accounting, tax and regulatory compliance;
We will not share your personal information with any other 3rd parties.
How long your personal information will be kept ?
We will hold your personal information for the following periods:
Contact details will be kept for 6 years to satisfy UK tax laws unless otherwise instructed by the HMRC.
These periods are no longer than necessary in each case.
Reasons we can collect and use your personal information
We rely on the following as the lawful basis on which we collect and use your personal information:
The legitimate interests relied upon are as follows:
To undertake criminal record checks to ensure employees are safe to work with children.
The information supports the business legitimate interests in promoting the well being of employees.
The information is used to ensure the appropriate employees are selected for work at third party sites.
Consequence of our use of your personal information
The consequence to you of our use of your personal information is:
Your personal information will be passed to the HMRC for tax purposes.
pension details will be passed to the relevant pension provider to enable them to contact you directly.
Keeping your information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
All personal information is held on our secure server which is password protected and encrypted
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Your obligations to safeguard personal data of others
In the course of your duties you may have access to the personal data of other individuals during the course of your employment. You must undertake any mandatory Sarah Harvey Limited data protection training, and ensure that you do not inappropriately obtain, retain, amend, use, delete, transmit or compromise the security of the personal data of others.
Failure to comply with your data protection obligations puts at risk the individuals whose personal information is being processed, carries the risk of significant civil and criminal sanctions for you and Sarah Harvey Limited and may, in some circumstances, amount to a criminal offence for which you are personally liable. Because of the importance of data protection obligations, it may lead to disciplinary action under our procedures, up to and including dismissal for gross misconduct.
If at any time you have any queries, you should contact us immediately.
Transfers of your information out of the EEA
We will not transfer your personal information outside of the EEA at any time.
What rights do you have?
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information
access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances
claim compensation for damages caused by our breach of any data protection laws
For further informaiton on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
email, call or write to us
let us have enough information to identify you
let us know the information to which your request relates
Do you need extra help?
If you would like this policy in another format (for example: audio, large print, braille) please contact us using the details below.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
By email and Company Intranet
Our data protection officer is Bob Home.
If you have any questions about this policy or the information we hold about you, please contact us by:
telephone: 01926 450545
(GDPR issue 1. Document raised by Sarah Harvey Limited, 37 Chandos Street, Leamington Spa, Warwickshire, CV32 4RL, 25/05/18 RJH)