|Company Name||IMPERIAL HOUSEHOLD STAFF LTD TRADING AS IMPERIAL NANNIES & GOVERNESSES, ‘WE,’ US’, ‘OUR’|
|Company Contact Details||Sarajane Ambrose at GDPR@Imperialstaff.com|
|Document DP5A||Privacy Notice (when personal data is obtained directly from the data subject)|
|Date||3rd February 2020|
Welcome to the Imperial Nannies & Governesses privacy notice.
Imperial Nannies respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), when you register with us or ask us to find you work, and when we place you in a role. This notice will also tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can request a pdf version of the policy by emailing GDPR@Imperialstaff.com
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Imperial Nannies collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for job alerts or newsletters, register as a candidate, search for jobs.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
IMPERIAL HOUSEHOLD STAFF LTD TRADING AS IMPERIAL NANNIES & GOVERNESSES, is the data controller and is responsible for your personal data (also referred to as “Imperial Nannies” “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Company Name: IMPERIAL HOUSEHOLD STAFF LTD TRADING AS IMPERIAL NANNIES & GOVERNESSES
Data Privacy Manager: Sarajane Ambrose
Address: IMPERIAL HOUSEHOLD STAFF LTD TRADING AS IMPERIAL NANNIES & GOVERNESSES,
10 Brick Street, Mayfair, London, W1J 7HQ
Telephone: +44 (0) 020 72339950
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or to your own country’s supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This is version one created on 4th February 2020 and for future reference historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Contact data including name, email address, address and phone number
- Device and browser data, such as IP address, information about your device and browser settings
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Where you have registered with us and/or we have placed you in a permanent or temporary role, we may also collect, use, store and transfer the following categories of your personal data:
- Employment and educational history data, such as CVs and job titles, qualifications and authorisations
- References where you have provided us with referees’ contact details
- Eligibility to work data such as passport and visa checks
Bank, tax and social security data such as account numbers, NI number, Unique Tax Reference (UTR)
- Your preferences such as preferred hours, location, salary etc.
Role data about roles in which you have been placed
Health data (in limited circumstances)
- Criminal convictions data (candidates only)
Where you have ask us to fill a vacancy, we may also collect the following information:
- Household details, including information about your home, family and pets;
- Role requirements, including preferences, job description, and person specification
Where you have provided a reference may also collect the following information:
- Reference, including information about your home, family and pets;
- Details about role, including dates and requirements
Sensitive personal data
We acknowledge the sensitivity of special categories of data such as information about health and criminal convictions, and will normally only ever process it when necessary to provide you with a safe place of work, to safeguard children or other vulnerable people, or to comply with legal or industry-specific requirements. We will only process sensitive data with your express consent, unless the processing of your sensitive personal data is necessary for other reasons permitted by law. Please do not disclose any sensitive personal data about yourself to us unless we request it or it is essential to do so. Unsolicited personal data will be deleted.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Where we collect or process any other categories of personal data (including sensitive personal data) about you that are not listed above, we will send you a separate Privacy Notice regarding the processing of such data by us.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you fail to provide with personal data when requested, we may not be able to provide you with work-finding or recruitment services.
3. HOW YOUR PERSONAL DATA COLLECTED
We may collect data about you when you register with us, visit our website, or when we communicate by email, SMS, phone or in person.
We use different methods to collect data from and about you from third parties:
- jobs boards, such as Reed, Total Jobs, Secs in the City, Caterer, Horticulture Job, Gumtree (subject to change)
- social media platforms, such as LinkedIn;
- analytics providers such as Google based outside the EU;
- search information providers such as Google and Internet Explorer based outside the EU;
- providers of technical, payment and delivery services such as Global Payments (linked to HSBC) based inside the EU;
- publicly available sources such as Companies House and the Electoral Register, based inside the EU.
4. HOW AND WHY WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have consented to our doing so.
In certain circumstances we are required to process certain categories of personal data in order to comply with our legal obligations under relevant legislation, including the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and other relevant tax, social security or other legislation. You are not under any obligation to provide us with your personal data, but if you do not we may be unable to meet our legal obligations and so may not be able to provide you with work-finding or recruitment services.
We also need to process certain categories of your personal data in order to enter into an agreement with you and to comply with our obligations under that agreement.
Where no contractual or legal obligation exists, we may still need to process your personal data in order to pursue our legitimate business interests. Our business involves providing work-finding and recruitment and related services and so we may need to process your personal data in order to pursue our legitimate interests in achieving this. We may also need to retain personal data in case we need to establish or defend a legal claim. We will balance our legitimate interests against your rights and freedoms and your legitimate interests and expectations.
In exceptional circumstances, we may rely on vital interests as the lawful basis for processing your personal data, in life or death situations.
If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Name, address, DOB||To verify your identity and CV or employment history, qualifications and authorisations||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Contact details||To communicate with you and notify you about suitable roles and other important information||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Role requirements||To find you the right candidate, role or assignment||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|CV, employment history, qualifications, authorisations||To check your suitability for a role or assignment||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|ID and immigration checks||To verify your identity and right to work||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Confirmation that you are willing to work in a particular role||To find you the right role or assignment||Legal obligation (if applicable). Legitimate interests.|
|Interview details||To set up interviews with hirers||Contractual obligation (if applicable). Legitimate interests.|
|Notes, assessments, comments, feedback from interview.||To find you the right role or assignment||Contractual obligation (if applicable). Legitimate interests.|
|Emails and correspondence with you and with potential hirers and intermediaries||To find you the right role or assignment||Contractual obligation (if applicable). Legitimate interests.|
|References (collected from third parties)||To verify your experience and suitability for a particular role or assignment||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Details of placement/assignment and hirer||To keep records of placements made or assignments arranged by us||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Credit history||Suitability checks||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests.|
|Candidate/work-finding Agreement||To set out the basis of the relationship between you and us||Contractual obligation (if applicable). Legitimate interests.|
|Sensitive personal data - health data||To check your suitability for a role or assignment and to ensure your health and safety||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests. Explicit consent or necessary for the performance of our employment or social security obligations|
|Sensitive personal data – criminal convictions||To check your suitability for certain roles or assignments||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests. Explicit consent or necessary for the performance of our employment or social security obligations|
|Bank details (temp only)||To pay you||Legal obligation (If applicable) Contractual performance.|
|Social security information, NI number (temp only)||To report to HMRC||Legal obligation (If applicable) Contractual performance.|
|Information about your pay and conditions (temp only)||To protect your rights||Legal obligation (if applicable).Contractual obligation (if applicable).Legitimate interests. Explicit consent or necessary for the performance of our employment or social security obligations|
|Household details & role requirements||To find a suitable candidate|
|Other necessary, relevant personal information||To perform our services for you||Contractual obligation (if applicable). Legitimate interests.|
|IP address, browser and device data||To deliver relevant website content and administer our website||Legitimate interests.|
We would like to use your contact details to contact you about news and information which we think may be of interest to you. However we will not contact you with marketing material unless you consent to our doing so.
You may also receive marketing communications from us if you have previously requested information or services from us and you did not opt out of receiving marketing communications from us at the time.
You have the right to unsubscribe at any time, by clicking the link which appears in the footer of all marketing emails.
We may use your personal data to end you automated job alerts with information about roles that may be of interest to you if you have asked us to do so.
You have the right to unsubscribe to automated job alerts at any time, by clicking on the link which appears in the email footers of marketing.
We will obtain your express opt-in consent before we share your personal data with third parties for marketing purposes.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share candidates’ personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Your personal information will be processed by our staff and our subcontractors (including IT providers) and will be provided to appropriate third parties such as potential hirers and intermediaries in order to provide you with work-finding services or to potential candidates in order to provide you with recruitment services. Please let us know if you do not want your personal information to be disclosed to a particular third party or category of third parties.
We may also share your personal details with your previous or current employers or other third parties identified by you to us as potential referees.
We may be required by law to share certain categories of candidates’ personal data with tax authorities and other government agencies.
We may use a third party organisation to check candidates’ references, criminal records, employment history and qualifications or to operate our payroll. We will need to provide them with certain categories of your personal data and they will be under an obligation to process it as instructed by us and in accordance with relevant data protection legislation. We may also need to provide certain categories of personal data to your pension provider, if appropriate.
We may also need to share your data with our professional advisers, such as lawyers and accountants.
We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We will not share your personal data with any other organisation unless it is necessary and in connection with providing our work-finding and recruitment services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Your personal data will be stored within the European Economic Area (EEA) on either local or cloud-based servers and will be subject to technical and organisation safeguarding protection measures. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Some categories of data may be transferred to organisations outside the EEA, including Interactive Manpower Solutions Private Limited in India. If it is necessary to transfer your data to a country outside the EEA to assist us in providing work-finding and recruitment services, we will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to technical and organisational safeguarding protection measures, as follows:
We will only transfer your personal data to organisations located in countries outside the EEA, if the organisation:
is based in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission, or
has entered into an agreement with us which contains specific contract clauses approved by the European Commission which give personal data the same protection that it has in Europe.
For further details, please see the following:
European Commission: Adequacy of the protection of personal data in non-EU countries
European Commission: Model contracts for the transfer of personal data to third countries
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security 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, agents, contractors and other third parties on a ‘need to know’ basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will only transfer personal data to a third party if they agree to comply with those procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
FOR HOW LONG WILL YOU USE OR RETAIN MY PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep certain information about candidates for between 1 and 7 years. Where we have entered into a contract with you, we may also need to retain data for up to 7 years in order to ensure that we can meet our contractual obligations to you.
As we place candidates in domestic settings, where candidates may work with children or vulnerable people, we may need to keep records about placements, candidates and clients for up to 21 years, in case of a later legal claim by a minor. In most cases, however, we will not need to keep personal data for this length of time.
As a general rule, if you have been placed by us, we will not retain data of your data for more than 21 years from the date of registration or the date of last placement (whichever is later) unless we have continued to have meaningful contact with you over the preceding 2 years.
If you have not been placed by us, we will not keep your data for more than 2 years from the date of registration or the date when we last had meaningful contact with you (whichever is later).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- request access to personal data we hold about you;
- object to the processing of your personal data;
- ask to have inaccurate data held about you removed or restricted;
- ask to have inaccurate data held about you or corrected;
- if processing of your personal data is based only on consent, to withdraw that consent;
- request that your personal data is shared with a third party in a commonly used, machine readable format.
If you wish to exercise any of the rights set out above, please contact us at SaraJane Ambrose at GDPR@Imperialstaff.com