1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the UK GDPR and the Data Protection Act 2018.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purposes of data protection regulation, we act as a data controller for our clients who deal directly with us, and as joint-controllers and processors for clients where we work on behalf of a third party.
2. ABOUT US
Lighthouse Personnel Ltd is a limited company registered in England under 11051734.
Our registered address is Unit 21, Langham Barns Business Centre, Langham Lane, Langham, Colchester, Essex CO4 5ZS.
We are registered as a Data Controller with the Information Commissioner’s Office. Reg no. ZA295048.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request information from us in respect of the services we provide. This could be from contact through our face-to-face meetings, website, email, telephone, social media or post.
- you or our clients engage us to provide our services and also during the provision of those services.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
· your personal details (such as your name, address, date of birth).
· details of contact we have had with you in relation to the provision, or the proposed provision, of our services (such as National Insurance number or ID verification).
· any relevant information relation to career history, which may be used to help assist searching for future employers
· IP address (automatically collected)
· our correspondence and communications with you.
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you, your employer or our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the DPA 2018 and the Privacy and Electronic Communications Regulations.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
- carry out our obligations arising from any agreements entered into between you, your employer or our clients and us (which will most usually be for the provision of our services).
- carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client.
- notify you about any changes to our services or policies.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
6. DATA RETENTION
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided.
- any statutory or legal obligations (for example 6 years +1 for HMRC).
- the purposes for which we originally collected the personal data.
- the lawful grounds on which we based our processing.
- the types of personal data we have collected.
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
7. CHANGE OF PURPOSE
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
8. CHANGE OF OWNERSHIP
We may, potentially, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of the business. Data provided by users will, where it is relevant to any part of our business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the data for the purposes for which it was originally collected by us.
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
All of our third-party service providers are required to take appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions. These are:
Tracker RMS https://www.tracker-rms.com/privacy-statement/
We may also need to share your personal data with a regulator or to otherwise comply with the law.
10. TRANSFERRING PERSONAL DATA OUTSIDE THE UK
We do not transfer personal data to third countries outside the UK that are not considered to provide an adequate level of data protection.
11. DATA SECURITY
We have put in place appropriate organisational and technical measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
All our staff have received Data Protection training annually.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
12. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact [email protected] or call 01206 984042
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our Privacy Officer. (See details below)
Alternatively, you can make a complaint to the Information Commissioner’s Office:
· Report a concern online at https://ico.org.uk/concerns/
· Call 0303 123 1113
· Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
14. CONTACT US
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Officer:
Phone: 01206 984042
Email: [email protected]
Email: [email protected]
This Notice was updated on 1st June 2021, however due to the decision of the UK to leave the EU the way your data is transferred from the UK to other countries may change. We may therefore update this Privacy Notice from time to time and we advise that you regularly check this page to ensure you are happy with the changes; we will however notify you of any significant changes