The HR Man acts as a sole trader and is aware of its obligations under the General Data Protection Regulation (GDPR) and current data protection legislation and is committed to processing your data securely and transparently. This privacy notice sets out, in line with data protection obligations, the types of data that I hold about you as a client or customer. It also sets out how I use that information, how long I keep it for and other relevant information about your data.

 

Data controller details

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The HR Man is a data controller, meaning that it determines the processes to be used when using your personal data. The contact details are as follows:

Rob Twyman (HR consultant)

07921 080507

rob@thehrman.co.uk

 

Data protection principles

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In relation to your personal data, I will:

 

• process it fairly, lawfully, and in a clear and transparent way

• collect your data only for reasons that I find proper for the provision of services within the course of your engagement

• only use it in the way that I have told you about

• ensure it is correct and up to date

• keep your data for only as long as I 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 (as appropriate), lost or destroyed.

 

Types of data I process

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I may hold different types of data about you or your employees, including:

 

• your personal details including your name, address, email address, and phone numbers

• gender

• date of birth

• marital status

• dependants, next of kin and their contact numbers

• bank details

• CCTV footage or audio files.

 

How I collect your data

 

I collect data about you in a variety of ways such as verbally, through emails and other written or electronic documents, including contracts of employment and right to work documents, video and audio files. This will usually start when I undertake to enter into a contract with you where I may collect the data from you or your business directly. Further information may be collected directly from you in the course of providing consultancy services once your engagement begins.

 

In some cases, I may collect data about you from third parties, such as intermediaries who may act as an introducer. Personal data is kept securely in an IT system.

 

Why I process your data

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The law on data protection allows me to process your data for certain reasons only:

 

• in order to perform the services that I am required to provide

• in order to carry out legally required duties

• in order for me to carry out my legitimate interests

• to protect your interests

• where something is done in the public interest and

• where I have obtained your consent.

 

All of the processing carried out by me falls into one of the permitted reasons. Generally, I will rely on the first three reasons set out above to process your data. For example, I need to collect your personal data in order to carry out the contract that I have entered into with you.

 

I also collect data so that I can carry out activities which are in the legitimate interests of the work. I have set these out below:

 

• making decisions about who to enter into a contract with

• dealing with legal claims made against me

• preventing fraud, and

• ensuring my administrative and IT systems are secure against unauthorised access.

 

Special categories of data

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Special categories of data may be collected relating to you or your employees as follows:

 

• health

• sex

• sexual orientation

• race

• ethnic origin

• political opinion

• religion

• trade union membership

• genetic or biometric data.

 

I must process special categories of data in accordance with more stringent guidelines. Most commonly, I will process special categories of data when the following applies:

 

• you have given explicit consent to the processing

• I must process the data in order to carry out our legal obligations

• I must process data for reasons of substantial public interest

• you have already made the data public.

 

I do not need your consent if I use special categories of personal data in order to carry out my legal obligations. However, I may ask for your consent to allow me 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.

 

Criminal conviction data

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I will only collect criminal conviction data where it is appropriate given the nature of your engagement with me and where the law permits me. This data will usually be collected during the engagement. I use criminal conviction data through the lawful basis of protecting the public interest to process this data.

 

If you do not provide your data to me

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One of the reasons for processing your data is to allow me to carry out my duties in line with the contract between us. If you do not provide me with the data needed to do this, I may be unable to perform those duties. I may also be prevented from confirming, or continuing with, your engagement with me.

 

Sharing your data

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Your data will not be shared with third parties unless one of the following exceptions applies:

 

• part of a company sale or restructure

• other reasons to comply with a legal obligation upon me.

 

Protecting your data

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I are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse.  I do not store your data outside of the UK.

 

How long I keep your data for

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In line with data protection principles, I only keep your data for as long as I need it, which will be at least for the duration of your engagement with me. Where the engagement has ended, your data will be kept for 12 months from the date of the final invoice.  

 

Automated decision making

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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

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The law on data protection gives you certain rights in relation to the data I hold on you. These are:

 

• the right to be informed. This means that I must tell you how I 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 I 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 I hold about you is incomplete or inaccurate, you are able to require me to correct it

• the right to have information deleted. If you would like me to stop processing your data, you have the right to ask me to delete it from our systems where you believe there is no reason for me to continue processing it

• the right to restrict the processing of the data. For example, if you believe the data I hold is incorrect, I will stop processing the data (whilst still holding it) until I have ensured that the data is correct

• the right to portability. You may transfer the data that I 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 I use your data where I 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 my use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that I will stop processing the data that you had previously given me consent to use. There will be no consequences for withdrawing your consent. However, in some cases, I 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 Rob Twyman on 07921 080507 or rob@thehrman.co.uk.

 

Making a complaint

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The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by me, you are able to make a complaint to the ICO.

 

 

Last update:

September 2024