Introduction GlobusHR Consulting Ltd ("We") are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the UK General Data Protection Regulation (the “UK GDPR”).
Data controller - A controller determines the purposes and means of processing personal data
Data processor - A processor is responsible for processing personal data on behalf of a controller
Data subject – Natural person
Data protection legislation – Means the data protection legislation enforce in the UK from time to time and includes the Data Protection 2018 (as amended) and the UK General Data Protection Regulation (UK GDPR)
Categories of data: Personal data and special categories of personal data
Personal data - The UK GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier (as explained in Article 6 of UK GDPR). For example, name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The UK GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of UK GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - Means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - Means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we? GlobusHR Consulting Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are as follows:
Postal address: 8 Barton Lane, Barton on Sea, New Milton England, BH25 7PL
GlobusHR Consulting Ltd is a company registered in England and Wales under Registered Number: 0799387.
For all data matters contact Sarah Hamilton-Gill FCIPD.
What information do we hold about you and why?
(a) Personal Data
We may collect, store, and use personal data about you (referred to as ‘personal information’) as follows:
Personal contact information; for example, your name, title, address, telephone number and email address
Where we are liaising in relation to recruitment, we may also collect personal information including passport or visa information, plus any other information which may be included in a job application form, CV or covering letter
Personal information passed on to us by a third party, for example a recruitment agency
Personal information gathered during an application process, including information given during any psychometric or profiling
Personal information from any interactions with our website, where for example you may have completed our ‘contact us’ form
(b) Special Data
In some circumstances we may need to collect ‘special data’ about you, as well as personal information:
When you have given us your consent to do so
When we need additional information; for example, but not limited to reviewing GP Fit notes, obtaining Occupational Health reports or reviewing absence records for employees
Where we need to comply with a legal obligation to which we are subject
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests
What is our legal basis for processing your personal data?
Personal data (article 6 of UK GDPR)
Our lawful basis for processing your general personal data:
Processing necessary general personal data to enable support and guidance
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
Processing necessary for compliance with a legal obligation
Our lawful basis for processing your special categories of data:
Explicit consent of the data subject
Processing necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement
Processing necessary for the establishment, exercise, or defence of legal claims or where courts are acting in their judicial capacity
Processing necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services based on data protection legislation or a contract with a health professional
More information on lawful processing can be found on the ICO website.
Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with those deemed necessary at GlobusHR Consulting Ltd including, but not limited to:
Our staff and associates
Recruitment professionals assisting with employment related matters
Technical support; eg website provider and software companies we use for marketing, CRM, finance system
Our professional advisers including accountants, legal support
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How long do we keep your personal data?
We keep your personal data only for as long as necessary to fulfil the purposes for which we collected it for. Where this relates to employment, this would be for the length your service, plus one year, in case of any legal claims/complaints.
Where we store your personal information Your personal and special information is stored electronically on cloud-based software .
These include CapsuleCRM, Xero financial software, Kajabi, Facebook, xxxxx.
Where their servers are based outside of the EEA (European Economic Area), we have taken steps to ensure your personal information is adequately protected and the transfer is lawful.
Your rights and your personal data
Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you
The right to request that we correct any personal data if it is found to be inaccurate or out of date
The right to request your personal data is erased where it is no longer necessary to retain such data
The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means)
The right to object to the processing of personal data, where applicable i.e., where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics)
Transfer of Data Abroad
We do not transfer personal data outside of the UK.
Automated Decision Making We do not use any form of automated decision making in our business.
Further processing If we wish to use your personal data for a new purpose, not covered by this Data Privacy 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.
How to make a complaint
To exercise all relevant rights, queries, or complaints please in the first instance contact Sarah Hamilton-Gill by post at 8 Barton Lane, Barton on Sea, New Milton England, BH25 7PL, telephone - 044 1590 637364, or email at [email protected]
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031 231 113 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, England.