PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Norton Loxley Ltd is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently.
This privacy notice sets out, in line with GDPR, the types of data that we hold on you as a prospective client, client, employee of our client or supplier to the Company. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
Norton Loxley Ltd is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:
Sian Whelan, Company Director, email@example.com.
Data protection principles
In relation to your personal data, we will:
- Process it fairly, lawfully and in a clear, transparent way.
- Collect your data only for reasons that we find proper for the course of our business relationship.
- Ensure it is correct and up to date.
- Keep your data for only as long as we need it.
- Process it in a way that ensures it will not be used for anything that you are not aware of or have not consented to (where appropriate).
Types of data we process
We process personal data about the following categories of people:
• Potential clients
• Other people involved in client matters we are providing HR and recruitment services to
• Referrers of work
• Other third parties we (including our employers, contractors and suppliers) that we have a business relationship with.
We hold many types of data about you, including:
• Your personal details including your name, address, email address, phone numbers.
• Our contracts, correspondence and transaction history as a user of our services or as a supplier.
• Client data, including any information in relation to the services we are providing, business and company relationships, personal circumstances, employment background and circumstances, services provided to clients or could be provided to potential clients and employee or prospective employee relationships.
• Bank details.
• Letters, contracts, meeting minutes and other documentation relating to employment advice and support we provide to our clients.
• Lists of delegates for any training events.
• Any marketing and communication preferences.
How we collect your data
We process and collect data about you in a variety of ways or the purposes of providing HR and recruitment services to our clients and prospective clients or as a supplier to us.
In addition, data about you may be obtained from other workplace sources (including, company systems and correspondence) during the course of providing our services.
Personal data is kept in hard copy files, email correspondence or within our IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
• Where we have your consent.
• In order to perform the contract and services that we are party to
• In order to carry out legally required duties.
• In order for us to carry out our legitimate interests.
• To protect your interests or where it is processed in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on performing our contractual obligations to process your data.
We also need to collect your data to ensure we are complying with any legal requirements.
We also collect data so that we can carry out activities which are in the legitimate interests of the Company.
If you have signed up to our newsletter via our website, you have explicitly consented to us processing your data.
Special categories of data
Special categories of data are data relating to your:
• sex life
• sexual orientation
• ethnic origin
• political opinion
• trade union membership
• genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
• you have given explicit consent to the processing
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
• you have already made the data public.
We will use your special category data:
• as required in client workforce matters where relevant.
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with our services provided to you. If you do not provide us with the data needed to do this, we will be unable to perform our services and duties eg providing HR advice.
Sharing your data
We may share your data with third parties involved in providing our services, including (but not limited to) legal and professional advisers with whom we work with, subcontractors and services such as accountancy marketing support services.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. eg backing up our servers, firewalls, access control for personal information, using password protected documents and encryption when transferring sensitive data, ensuring our IT systems that process personal information are secure to GDPR standards.
We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know and who will only process your personal information on our instruction.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of our business relationship and for six years after our contract/s has ended for HMRC record keeping and the defence of potential legal claims.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
• The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
• The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
• The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
• The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• The right to portability. You may transfer the data that we hold on you for your own purposes.
• The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.
• The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact the Data Controller listed above.
Making a complaint
We hope this privacy notice has been helpful in setting out how we handle your personal data. If you have any questions or a query that hasn’t been covered, please contact us by email in the first instance at firstname.lastname@example.org.
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Last reviewed: July 2020