Your personal data – what is it?
“Personal data” can refer to any information that is related to an identifiable natural person. Examples can include a name, photographs, email address, address etc. The processing of personal data is governed by the Data Protection Bill/Act 2017 the General Data Protection Regulation 2016/679 (the “GDPR”) and other legislation relating to personal data and rights such as the Human Rights Act 1998.
Who are we?
This Privacy Notice is provided to you by ConiferGB who is the data controller for your data. ConiferGB is a Security and Hospitality staffing company. We provide SIA qualified security guards, professional and experienced hotel staff. We aim to deliver the best quality service our clients expect.
What data do the data controllers listed above process?
The data control person will process some or all of the following where necessary to perform their tasks:
- Names, titles, and photographs;
- Contact details such as telephone numbers, emails, home addresses.
- Where they are relevant to our mission, or where you provide them to us, we may process demographic information such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications
- Financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers.
How do we process your personal data?
The data controllers will comply with their legal obligations to keep personal data up to date; to store and destroy it securely; to not collect or retain excessive amounts of data; to keep personal data secure, and to protect personal data from loss, misuse, unauthorised access and disclosure and to ensure that appropriate technical measures are in place to protect personal data.
We use your personal data for some or all of the following purposes:
- To enable us to meet all legal and statutory obligations (which includes maintaining the Staff Details records)
- To enable us to meet payment deadlines (paying staff on a monthly basis)
- To maintain our own accounts and records;
- To notify you of changes to pay (increase in minimum wage)
- To send you communications which you have requested and that may be of interest to you. These may include information about pay, hours, client requirements, your performance etc.
- To process an application for a role applied.
What is the legal basis for processing your personal data?
Most of our data is processed because it is necessary for our legitimate interests (references noted down on application forms). An example of this would be contacting references and confirming with them how long you were employed with their company. We will always take into account your interests, rights and freedoms.
We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with employment under ConiferGB.
Where your information is used other than in accordance with one of these legal bases, we will first obtain your consent to that use.
Sharing your personal data
Your personal data will be treated as strictly confidential. It will only be shared with third parties where it is necessary for the performance of our tasks or where you first give us your prior consent. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- Contacting references that are provided on the application; personal data will be shared with third parties that are only on the application form.
- Personal data will be shared with the client – If you are employed under ConiferGB, the client will need to know certain information e.g. name, telephone and mobile number, email.
- The Company Accountant will need personal data e.g. N.I numbers, P45s, Home addresses.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, it is current best practice to keep financial records for a minimum period of 7 years to support HMRC audits. In general, we will endeavour to keep data only for as long as we need it. This means that we may delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access information we hold on you
- At any point you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we obtained the information from. Once we have received your request we will respond within two weeks.
- There are no fees or charges for requests.
- The right to correct and update the information we hold on you
- If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
- The right to have your information erased
- If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold.
- When we receive your request we will confirm whether the data has been deleted or the reason why it cannot be deleted (for example because we need it for our legitimate interests or regulatory purpose(s)).
- The right to object to processing of your data
- You have the right to request that we stop processing your data. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or to bring or defend legal claims.
- The right to data portability
- You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was sought.
- You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
- The right to object to the processing of personal data where applicable.
- The right to lodge a complaint with the Information Commissioner’s Office.
If we wish to use your personal data for a new purpose, not covered by this Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Please contact us if you have any questions about this Privacy Notice or the information we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller: Miss Eugenie Kamau, ConiferGB Head Office, 1 Empire Mews, London, SW16 2BF. Email:firstname.lastname@example.org, Contact details: 02071835347.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.