Privacy Notice

Privacy Notice – May 2018

Should you have a question about any of these Privacy Notices or the information we store, please contact the Director of IHAG by email or by post to the Director,  IHAG, 22 – 24 Carr Street, Ipswich IP4 1EJ or by phone on 01473-213102

Index

(Click on links below to jump to section – Ctrl + Home takes you back to the index)

Overarching Privacy Notice

Specific Privacy Notices:

A.          Advice Services – Chapman Centre and Money Advice

B          Housing

C          Framework Forum

D          Money Advice Forum

E           ILHP Network

F           Websites/Social Media

G          Employees

Overarching Privacy Notice

1              Introduction

IHAG respects your privacy and is committed to protecting your personal data. This privacy notice will provide you with information about how we look after your personal data and tell you about your privacy rights and how the law protects you.

This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 personal data. This privacy notice supplements those other notices and is not intended to override them

IHAG holds a wide range of data and information on individuals and organisations for the purpose of carrying out its charitable Objects which are:

“(a)         to relieve need, hardship and distress amongst the homeless and amongst those who are living in adverse housing conditions in Ipswich and the surrounding districts

(b)          the relief of financial hardship among people living or working in the Borough of Ipswich and its surrounding area; and

(c)           to relieve unemployment for the public benefit in such ways as may be thought fit, including assistance to find employment.”

2              Legally Required Data Protection Principles

The data protection principles set out the main responsibilities for organisations.  Personal data shall be:

“a) processed lawfully, fairly and in a transparent manner;

b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) accurate and, where necessary, kept up to date;

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and

f) processed in a manner that ensures appropriate security of the personal data”

3              IHAG’s Data Protection Values

At IHAG we collect and use your personal information to help solve your problems, improve our services and tackle wider issues in society that affect people’s lives.

For these reasons:

  • We only ask for the information we need
  • We always let you decide what you’re comfortable telling us, explain why we need it and treat it as confidential
  • When we record and use your personal information we:
    • only access it when we have a good reason
    • only share what is necessary and relevant
    • don’t sell it to anyone
    • only keep it as long as is necessary or required by law
  • We handle and store your personal information in line with the law

Privacy Notices will always consist of the following Sections:

1.       The Information we Collect from you

2.       How the Information is Collected

3.       When we will use your Personal Information

4.       How long we will keep your Information

5.       Disclosure/Data Sharing

6.       Opting out

Additionally, depending on relevance and appropriateness, the following may be included

7.       Sensitive Personal Information

8.       Information about Criminal Convictions

9.       Your Duty to inform us of Changes

10.   Failure to Provide Information

11.   Transfers of Data Outside of the EU

12.   Your Rights

13.   Complaints & Questions

14.   Changes to this Privacy Notice

4              Managing Data on the Behalf of Others

Where IHAG, or a particular IHAG staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that IHAG will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.

5              Specific Privacy Notices

To facilitate the different ways that you interact with IHAG, there are specific Privacy Notice for each type of interaction as set out below and linked to that specific Notice by clicking on the heading:

A          Advice Services – Chapman Centre and Money Advice

B          Housing

C          Framework Forum

D          Money Advice Forum

E           ILHP Network

F           Websites/Social Media

G          Employees

 

Section A

Advice Services Privacy Notice – Chapman Centre and Money Advice

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

IHAG is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.

This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.

For more information please contact the Data Protection Officer, (the Director of IHAG), who will provide you with our Data Protection Policy.

The Information we Collect from you

Personal data includes 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 will collect, store, and use the following categories of personal information about you:

  • Personal contact details, such as: name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Marital status and dependants
  • National Insurance number
  • Employment details, such as hours and evidence of pay
  • Financial details, such as your income, expenditure, debt and bank account details
  • Housing details, such as your housing provider, arrears and court action taken against your home
  • Details of other agencies/organisations you are working with

Sensitive Personal Information and Information about Criminal Convictions

We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:

  •  Information about your health, including any medical condition, health and sickness records
  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
  •  Information about criminal convictions and offences

How the Information is Collected 

We may use the following ways to collect personal information about you, from when you are initially referred to the service until you are no longer receiving advice from us or your case is closed:

  • Directly by you.  This may be by telephone, post, face to face, email or through an online web form
  • Indirectly by third parties, such as agencies that provide(d) services to you or that you owe money to, friends and family or other professionals
  • CCTV images (only used in communal areas for security and safety reasons)

When we will use your Personal Information

We may use your information for a number of different purposes, which include:

  • providing you with advice, assistance or information
  • keeping a record of your case so that we can keep you informed of work undertaken and provide ongoing advice tailored to your needs
  • signposting/referring you to other relevant services/agencies
  • providing a safe mailing address (Chapman Centre only)
  • helping us to monitor, audit and improve our services
  • seeking your feedback on the services we provide
  • reporting to our contractors/funders
  • sharing appropriate information with contractors who need to work in areas you occupy or use
  • sharing safeguarding concerns to help keep you safe

The Legal Basis for processing your Personal Data

We process personal data if it is necessary to deliver a service to you.   The law sets out six available lawful bases for processing your data:

  • Legal obligation to comply with law (such as we can pass on details of fraud or other criminal activity)
  • Contract necessary to fulfil contractual responsibilities (or have been asked to do prior to entering a contract).  For example, to meet our contractual obligations with a Grantor/Funder
  • Legitimate interest; the processing is necessary for your legitimate interests (used in way you would reasonably expect) or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests (for example, for internal and external auditing and quality assurance purposes or to meet Regulatory requirements)
  • Life or death; the need to protect someone’s life
  • Public interest; carrying out a task in the public interest
  • Consent clear consent given to process personal data for specific purpose (specific, unambiguous, separate (e.g. separate form), revocable).

Disclosure/Data Sharing

We will get your permission by either signing a consent form or verbally over the telephone, to share information with other organisations:

  • to enable us to advise or assist you (such as sharing your personal information with local housing providers and grant giving agencies)
  • to refer you to other agencies for advice or support
  • for training, quality and auditing purposes (such as peer reviews and the Advice Quality Standard)

Safeguarding

Children and vulnerable adults are recognised as needing protection.  If someone is identified as being at risk from harm we have a responsibility to protect them.  There are laws in place allowing us to share safeguarding concerns with other relevant agencies whether or not consent is given.

Transfers of Data Outside of the EU

We may transfer the personal information we collect about you outside the EU in order to perform our contract with you.  We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations.  Further information is available from the Data Protection Officer, (the Director of IHAG).

For how long we keep your Data

If we provide advice or undertake casework (that is, an Adviser assists you over a period of time), we keep your information for 6 years (or 7 for tax information) from when we close your case and then anonymise it.

If you never receive advice, we keep your information for 1 year following referral to our service.

If you use the Chapman Centre as a safe mailing address and do not collect your mail within three months, we will seek to return it to the sender.  Where this is not possible, we will destroy it.

CCTV images are normally kept for a maximum of 6 weeks unless there is an incident, which requires us to keep it for longer (for example, if we receive a legal request to provide CCTV images by the court or the police).

If you have been involved in a serious incident at IHAG, we may keep relevant personal data for longer than the periods detailed above.

Your Rights

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 ground.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

For Chapman Centre, please contact admin@ihagcc.co.uk or telephone 01473 232426 and inform us of the consent you wish to withdraw.

For Money Advice, please contact mas@ihag.co.uk or telephone 01473 213102 (Option 1 for the Money Advice department) and inform us of the consent you wish to withdraw.

Complaints & Questions

If you have any questions about this privacy notice or how we handle your personal information, please contact a Manager.  If we have breached our duty of care, we will take appropriate action.

If you are not satisfied by our response you also 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 (Emailcasework@ico.org.uk)

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

Section B

Housing (in relation to Housing Related Support)

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

IHAG is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.

This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.

For more information please contact the Data Protection Officer, (the Director of IHAG), who will provide you with our Data Protection Policy.

The Information we Collect from you

Personal data includes 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 will collect, store, and use the following categories of personal information about you:

  • Personal contact details, such as: name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Marital status and dependants
  • National Insurance number
  • Employment details, such as hours and evidence of pay
  • Financial details, such as your income, expenditure, debt and bank account details
  • Housing details, such as your housing provider (current and former), arrears and court action taken against your home
  • Details of other agencies/organisations you are working with

Sensitive Personal Information and Information about Criminal Convictions

We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:

  • Information about your health, including any medical condition, health and sickness records
  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
  • Information about criminal convictions and offences

How the Information is Collected 

We may use the following ways to collect personal information about you, from when you are initially referred to the service until you are no longer receiving advice from us or your case is closed:

  • Directly by you.  This may be by telephone, post, face to face, email or through an online web form
  • Indirectly by third parties, such as agencies that provide(d) services to you or that you owe money to, friends and family or other professionals
  • CCTV images (only used in communal areas for security and safety reasons)

When we will use your Personal Information

We may use your information for a number of different purposes, which include:

  • providing you with housing related support and accommodation
  • providing you with advice, assistance or information
  • keeping a record of your case so that we can keep you informed of work undertaken and provide ongoing advice and support tailored to your needs
  • signposting/referring you to other relevant services/agencies
  • providing a safe mailing address
  • helping us to monitor, audit and improve our services
  • seeking your feedback on the services we provide
  • reporting to our contractors/funders/landlords
  • sharing appropriate information with contractors who need to work in areas you occupy or use
  • sharing safeguarding concerns to help keep you safe

The Legal Basis for processing your Personal Data

We process personal data if it is necessary to deliver a service to you.   The law sets out six available lawful bases for processing your data:

  • Legal obligation to comply with law (such as we can pass on details of fraud or other criminal activity)
  • Contract necessary to fulfil contractual responsibilities (or have been asked to do prior to entering a contract).  For example, to meet our contractual obligations with a Grantor/Funder
  • Legitimate interest; the processing is necessary for your legitimate interests (used in way you would reasonably expect) or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests (for example, for internal and external auditing and quality assurance purposes or to meet Regulatory requirements)
  • Life or death; the need to protect someone’s life
  • Public interest; carrying out a task in the public interest
  • Consent; clear consent given to process personal data for specific purpose (specific, unambiguous, separate (e.g. separate form), revocable).

Disclosure/Data Sharing

We will get your permission by either signing a consent form or verbally over the telephone, to share information with other organisations:

  • to enable us to advise or assist you (such as sharing your personal information with local housing providers and grant giving agencies)
  • to refer you to other agencies for advice or support
  • for training, quality and auditing purposes (such as Housing Related Support reviews)

Safeguarding

Children and vulnerable adults are recognised as needing protection.  If someone is identified as being at risk from harm we have a responsibility to protect them.  There are laws in place allowing us to share safeguarding concerns with other relevant agencies whether or not consent is given.

Transfers of Data Outside of the EU

We may transfer the personal information we collect about you outside the EU in order to perform our contract with you.  We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations.  Further information is available from the Data Protection Officer, the Director of IHAG.

For how long we keep your Data

We keep case notes and other information for no longer than 6 years, except where we have a legal and legitimate reason to keep it for longer (such as licence agreements, debt owed to IHAG and serious incidents involving you).  In most cases information will be handed back to you on exiting the service (such as proof of income).

If you continue to use IHAG as a safe mailing address after exiting the service, we will help you to seek an  alternative address, to which we will forward your mail.  If you do not collect your mail within one month, we will seek to return it to the sender.  Where this is not possible, we will destroy it.

CCTV images are normally kept for a maximum of 7 days unless there is an incident, which requires us to keep it for longer (for example, if we receive a legal request to provide CCTV images by the court or the police).

Your Rights

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 ground.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

If you wish to withdraw consent, please contact your Housing Support Co-ordinator (if you are currently housed or receiving a service from IHAG’s Housing Team) or ruth@ihag.co.uk  or telephone 01473 213102 (Option 2 for the Housing department) and inform us of the consent you wish to withdraw.

Complaints & Questions

If you have any questions about this privacy notice or how we handle your personal information, please contact a Manager.  If we have breached our duty of care, we will take appropriate action.

If you are not satisfied by our response you also 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 (Emailcasework@ico.org.uk)

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

Section C

Framework Forum

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

The ILHP will hold your contact details, and those of your organisation, for the sole purpose of keeping in touch with you and your organisation about the ILHP and ILHP related issues.

We will keep your contact details safe and secure and will never sell, market or in any other way use your contact details.

To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.

The ILHP Manager is employed by IHAG and  therefore is subject to IHAG’s Privacy Statement, the relevant passage of which states:

“Where IHAG, or a particular IHAG staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that IHAG will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.”

To aid effective communication, when we email the ILHP network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique.   Recipients will not use the ‘cc’ addresses to ‘reply to all’ unless specifically requested to do so.

In this way, the integrity of the ILHP communiques are maintained and are not used by recipients to contact the whole network.   Should people wish to contact the whole network, they are expected to do so by contacting the Locality Manager and they will manage the communication if appropriate.

 

Section D

Money Advice Forum

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

IHAG’s Money Advice Service team are subject to IHAG’s Privacy Notice, the relevant passage of which states:

“Where IHAG, or a particular IHAG staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that IHAG will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.”

IHAG’s Money Advice Service will hold your contact details for the sole purpose of keeping in touch with you about the Money Advice Forum (MAF) and MAF related issues.

We will keep your contact details safe and secure and will never sell market or in any other way use your contact details.

To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.

To aid effective communication, when we email the MAF network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique.

 

Section E

ILHP – Privacy Statement

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

The ILHP will hold your contact details, and those of your organisation, for the sole purpose of keeping in touch with you and your organisation about the ILHP and ILHP related issues.

We will keep your contact details safe and secure and will never sell, market or in any other way use your contact details.

To opt out of this network, please click here and send the auto-generated email with an explanation if at all possible.

The ILHP Manager is employed by IHAG and  therefore is subject to IHAG’s Privacy Statement, the relevant passage of which states:

“Where IHAG, or a particular IHAG staff member, manages a professional network/forum, the specific network will have its own privacy statement that relates specifically to that network and which will set out the information that IHAG will hold, the reason for holding that information, what we will and will not do with that information and a simple option to opt out.”

To aid effective communication, when we email the ILHP network, we will show the names and email addresses of all the recipients – in this way you will know who else has received the communique.   Recipients will not use the ‘cc’ addresses to ‘reply to all’ unless specifically requested to do so.

In this way, the integrity of the ILHP communiques are maintained and are not used by recipients to contact the whole network.   Should people wish to contact the whole network, they are expected to do so by contacting the Locality Manager and they will manage the communication if appropriate.

 

Section F

Websites/Social Media – Privacy Statement

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here.

Cookies

Cookies are small text files that are placed on your computer or smartphone by websites that you visit. They allow the website to recognise your device and store some information about your preferences or past actions.  They are also used to make websites work or work more efficiently.

How we use cookies:

When the website opens it will ask you if a Cookie can be placed on your computer’s hard drive. Once you agree, the file is added and the Cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We also use traffic log cookies to identify which pages are being used so that we can analyse data about web page traffic and improve the website experience for our visitors.

Please note that we only use this information for statistical analysis purposes and then the data is removed from the system.

Our cookies never gives us access to your computer or any information about you, other than the data you choose to share with us.

Should you wish, you can choose to decline cookies.  Your web browser will normally automatically accept cookies, but you can usually modify its settings to decline cookies if you prefer. We suggest consulting the Help section of your browser or taking a look at the following websites www.aboutcookies.org or www.allaboutcookies.org which will tell you about cookies and how to remove them from your browser.  However. in a few cases. some of our website features may not function as a result.

Google Analytics

The IHAG is website sets “first party” cookies through its use of Google Analytics.   We use Google Analytics to provide us with non-personal site analytics, which in turn help us improve this website. Google Analytics tracking uses cookies in order to provide meaningful reports about web site visitors’ but they do not collect personal data about you. Google Analytics sets or updates cookies only to collect data required for the reports.  Additionally, Google Analytics only uses first-party cookies. This means that all cookies set by Google Analytics cannot be altered or retrieved by any service on any domain other than [yourdomain.com].  Further detailed information on Google Analytics cookies can be found here.

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you visit to other websites you should read their own privacy policies.

Media – Photographs / Recordings / Videos / Filming

We may use media (photographs, recordings, videos and film) for purposes of publication, display or broadcast (print, web, social media, digital display and all other forms of media and promotion).  Data which identifies an individual, even without a name associated with it, may be personal data if you are processing it to learn or record something about that individual, or where the processing has an impact on that individual.  If the media “relates to” an individual, we will ensure they sign a disclaimer/release form (or in some cases, verbally consent) to enable us to, for example, publish the media.

Right to Withdraw Consent  

If you are included in any piece of media and would like to be removed, please contact maureen@ihag.co.uk and inform us of the media you wish to be removed.

 

Section G

Employee – Privacy Notice

This Privacy Notice is subject to IHAG’s overarching Privacy Notice which can be found here

IHAG is committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.

This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights about data that we hold about you.

It applies to current and former employees, workers, volunteers, interns and contractors and does not form part of any contract of employment or other contract to provide services.

For more information please contact the Data Protection Officer, (the Director of IHAG), who will provide you with our Data Protection Policy.

The Information we Collect from you

Personal individual 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 will collect, store, and use the following categories of personal information about you:

1.       Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses. [PC]

2.       Date of birth. [DOB]

3.       Gender. [G]

4.       Marital status and dependants. [MSD]

5.       Next of kin and emergency contact information. [NOK]

6.       National Insurance number. [NI]

7.       Bank account details, payroll records, travel logs and expenses and tax status information. [BD]

8.       Salary, annual leave, pension and benefits information. [SI]

9.       Start date. [SD]

10.   Location of employment or workplace. [LOE]

11.   DVLA Information, including MOT, Insurance and driving licence details. (DVLA)

12.   Recruitment information (including copies of right to work documentation, passport, references and other information included in a CV or cover letter or as part of the application process). [RI]

13.   Employment records (including job titles, work history, working hours, training records and professional memberships). [ER]

14.   Compensation history. [CH]

15.   Performance, supervision and appraisal information. [PI]

16.   Disciplinary and grievance information. [DG]

17.   CCTV footage and other information obtained through electronic means such as swipe card records. [CCTV]

18.   Information about your use of our information and communications systems. [ICS]

19.   Photographs.[P]

We may also collect, store and use “special categories” of more sensitive personal data which require a higher level of protection:

20.   Information about your health, including any medical condition, health and sickness records (including Occupational Health records). [HR]

21.   Absence notes [AN]

22.   Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions. [DI]

23.   Information about criminal convictions and offences.  DBS information and access to current information whilst an employee. [CC]

How the Information is Collected 

We collect personal information through the application and recruitment process, either directly from candidates or sometimes from an employment agency.  We may sometimes collect additional information from third parties including former employers or other background check agencies.  We may collect additional personal information in the course of job-related activities throughout the period of you working for us.

When we will use your Personal Information

We need all the categories of information identified above primarily to allow us to perform our contract with you[*] and to enable us to comply with legal obligations[**].  In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties[***] (provided your interests and fundamental rights do not override those interests).  We will process your personal information as follows, the asterisks show the purpose for processing:

 

 Purpose Type of data Lawful basis
Making a decision about your recruitment or appointment. PC,  DVLA, RI, CC ***
Determining the terms on which you work for us. SI, SD, LOE, RI, ER ***  *
Checking you are legally entitled to work in the UK. PC, DOB, NI, RI **
Paying you and, if you are an employee, deducting tax and National Insurance contributions. PC, DOB, NI, BD, SI, AN ** *
Liaising with your pension provider. PC, DOB, NI, SI, SD *
Administering the contract we have entered into with you. PC, NOK, NI, BD, SI, SD, LOE, PI, DG, HR, AN *** *
Business management and planning, including accounting and auditing. PC, NI, BD, SI, SD, LOE, ER, CH, PI, DG, CCTV, ICS, HR, TU ***
Conducting performance reviews, managing performance and determining performance requirements. PC, SI, SD, LOE, ER, PI, DG, CCTV, ICS, HR, AN *** *
Making decisions about salary reviews and compensation. PC, DOB, BD, SI, SD, LOE, RI, ER, CH, PI, DG *** *
Assessing qualifications for a particular job or task, including decisions about promotions. PC, RI, ER, PI, DG *** *
Gathering evidence for possible grievance or disciplinary hearings.

Making decisions about your continued employment or engagement.

PC, DOB, G, MSD, PI, DG, CCTV, ICS, HR, AN, DI

PC, PI, DG, CCTV, ICS, HR, AN

*** *
Making arrangements for the termination of our working relationship. PC, DOB, NI, BD, SI, SD, ER, PI, DG, HR, AN *** *
Education, training and development requirements. PC, RI, ER, PI, DG *** *
Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work. PC, DOB, G, MSD, BD, SI, SD, LOE, RI, ER, CH, PI, DG, CCTV, ICS, P, HR, AN, DI, TU, GBD ***
Ascertaining your fitness to work and managing sickness absence. PC, DOB, G, NOK, LOE, PI, DG, CCTV, P, HR, AN *** *
Complying with health and safety obligations. PC, NOK, LOE, CCTV, P, HR, AN ** *
To prevent fraud. PC, NI, BD, DVLA, RI, ER, CCTV, ICS, P, CC *** **
To monitor your use of our information and communication systems to ensure compliance with our IT policies. PC, CCTV, ICS ***
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. PC, CCTV, ICS ***
To conduct data analytics studies to review and better understand employee retention and attrition rates. PC, DOB, G, MSD, HR, DI ***
Equal opportunities monitoring. PC, DOB, G, MSD, HR, DI *** **

 

Please refer to our Data Protection Policy which provides more detail on how we collect your data, the basis on which we hold it and how we store, use and destroy it.

Failure to Provide Information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing employee benefits), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Sensitive Personal Information  

“Special categories” of particularly sensitive personal information require higher levels of protection. We may process special categories of personal information in the following circumstances:

1.       In limited circumstances, with your explicit written consent.

2.       Where we need to carry out our legal obligations and in line with our Data Protection Policy.

3.       Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to a pension scheme, and in line with our Data Protection Policy.

4.       Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.  We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.

Our Obligations as an Employer

We will use your particularly sensitive personal information in the following ways:

We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about Criminal Convictions

We may only use information relating to criminal convictions where the law allows us to do so.  This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.

We envisage that we will hold information about criminal convictions and access your DBS portal.

Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

We are allowed to use your personal information in this way.

Your Duty to inform us of Changes

It is important that the personal information we hold about you is accurate and current, so please let us know if your information changes.

Disclosure/Data Sharing

We may have to share your data with third parties, including third-party service providers (including contractors and designated agents); other entities in the group; in the context of a sale of the business; or with a regulator or to otherwise comply with the law; our insurers and/or professional advisers to manage risks legal disputes.

We do this where required by law; where it is necessary to administer the working relationship with you; or where we have another legitimate interest in doing so.

We contractually require third party contractors to respect the security of your data and to treat it in accordance with the law.

Currently the only third-party service providers who process personal information about you are our HR consultancy firm (HR Department), AC Contracts (Allen Clarke ) who delivers our IT support, and HMRC (the Tax office) which operates the RTI system (real Time Information) to adjust monitor your earnings and Tax.

Additionally, each year our Auditors carry out a full audit of our finances (this required by Law) and they have access to the payroll system to check that we have managed it correctly.

Transfers of Data Outside of the EU

We may transfer the personal information we collect about you outside the EU in order to perform our contract with you.  We use Microsoft Office365 services which cover our email and other cloud-based services, these services are based on a UK geo location but some of those services may be hosted across other locations.  Further information is available from the Data Protection Officer, the Director of IHAG.

Data Retention

We must store most of your HR data for a period of at least 6 years following the termination of your employment; some personal financial data will be destroyed after 2 years; Health and Safety information must be held for a minimum of 40 years.

Your Rights

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

•         Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.  Please refer to our DSAR Procedure for more information.

  • Request correction of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information.  This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 ground.  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 information.  This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

Right to Withdraw Consent  

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  Please contact the person responsible for Data Protection in our Company.

Complaints & Questions

If you have any questions about this privacy notice or how we handle your personal information, please contact the person responsible for Data Protection in our Company.  If we have breached our duty of care, we will take appropriate action.

If you are not satisfied by our response you also 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 (Emailcasework@ico.org.uk)

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

I have read and understood the above notice:

Name:

 

Signature: ………………………………..      Printed: ………………………………..        Dated:     /     /