PRIVACY NOTICE
Issue 04/012023
IN THIS ISSUE
- Personal information collection
- Categories of personal information
- Reasons for collection of information
- Uses made of information
- Direct marketing
- Disclosure of information
- Transfer of information
- Timescales
- Your rights
- Changes to this notice
- Contact details
INTRODUCTION
Who We Are
Paramount Trades and Labour’s registered office address is
Suite G01, Eagle House, 167 City Road, London, EC1V 1AW.
We are a company registered in England and Wales under company number 7485471. Our company is registered on the Information Commissioner’s Office Register: registration number ZA345508, and act as the data controller when processing your data. Our designated Appointed Person is Nelly Hristeva, who can be contacted at: Suite G01, Eagle House, 167 City Road, London, EC1V 1AW or email: nelly@ptl.agency.
Paramount Trades and Labour Ltd (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after job search with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.
This notice applies to you if you are either:
- an individual (‘candidate’) who has registered his/her interest in finding placement;
- a worker who is currently on a placement through us;
- a client, who has asked us to find candidates for them; or
- a supplier to us with whom we have or have had a working relationship.
References to we, our or us in this privacy notice are to the Paramount Trades and Labour Limited.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR & Operations Manager has overall responsibility for data protection compliance in our organisation.
Contact details are set out in the “Contacting us” section at the end of this privacy notice.
Paramount Trades and Labour Ltd (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data
- PERSONAL INFORMATION WE MAY COLLECT FROM YOU
When you sign up with us, you may provide us with or we may obtain personal information about you, such as information regarding your:
- personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers;
- date of birth;
- gender;
- trade, qualifications and membership details including start and end date;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- records of your placement; and
- your marketing preferences so that we know whether and how we should contact you.
Individuals/Candidates/Workers
If you are an individual who has registered his/her interest in finding employment, you may also provide us with or we may obtain the following additional personal information from you:
- identification documents such as passport and identity cards;
- details of nationality and working visa’s;
- details of next of kin, family members, emergency contacts;
- any disciplinary and grievance information;
- any details required for the purposes of you taking up placement with one of our clients; and
- banking details that are provided to your nominated umbrella company/payroll bureau so that you can be paid.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:
- information about your race or ethnicity, religious beliefs and sexual orientation;
- information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
- biometric information about you, for example fingerprints, retina scans.
We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that
- the processing is necessary for reasons of substantial public interest, on a lawful basis;
- it is necessary for the establishment, exercise or defence of legal claims;
- it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
- based on your explicit consent.
- It is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.
In the table below, we refer to these as the “special category reasons for processing of your personal data”.
We may also collect criminal records information from you. For criminal records history, we process it on the basis of legal obligations or based on your explicit consent.
3. WHERE WE COLLECT YOUR INFORMATION
We typically collect personal information about our candidates when you sign up with us or apply for a position, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.
If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how, what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.
4. USES MADE OF THE INFORMATION
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
Purpose | Personal information used | Lawful basis |
All Candidates | ||
To administer any candidates account(s) you have with us and managing our relationship with you, [including arranging for any insurance] and dealing with payments and any support, service or enquiries made by you | All contact details, transaction and payment information, records of your interactions with us, and marketing preferences. | This is necessary to enable us to properly manage and administer your relationship with us. |
To arrange and manage any agreements for the provision of any merchandise, products and/ or services (finding job assignments/placements) |
All contact details.
Transaction and payment information. |
This is necessary to enable us to properly administer and perform any agreement for the provision of placement services. |
To send you information which is included within our placement/assignment service | All contact details
|
This is necessary to enable us to properly manage and administer your agreement with us and for the purpose of our legitimate interest of offering you job placements. |
To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about other roles, events, participation products and information. | All contact details and marketing preferences | Where you have given us your explicit consent to do so. NB. Need for consent for any direct marketing that is not included as part of our normal candidate package. |
To answer your queries or complaints | Contact details and records of your interactions with us | We have a legitimate interest to provide complaint-handling services to you in case there are any issues with your assignment/placement roles. |
Retention of records | All the personal information we collect | We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your records and in some cases, we may have legal or regulatory obligations to retain records.We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
The security of our IT systems | Your usage of our IT systems and online portals. | We have a legitimate interest to ensure that our IT systems are secure. |
To conduct data analytics studies to better understand attendance and trends within the work that we do | Records of your attendance at any jobs or events hosted by us. | We have a legitimate interest in doing so to ensure that our records are accurate and relevant. |
For the purposes of promoting our business and new opportunities. | Images in video and/or photographic form. | Where you have given us your explicit consent to do so. |
To comply with health and safety requirements | Records of attendance | We have a legal obligation and a legitimate interest to provide you and other candidates and staff with a safe environment in which to operate. |
To conduct performance reviews, manage performance and determine performance requirements and administer your development and training requirements. | All performance and attendance data and information about your health and medical condition.
Details of any qualifications or memberships. |
This is necessary to enable us to properly manage and administer your development.
It also allows us to find the appropriate roles for you. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To gather evidence for possible grievance or disciplinary hearings | All the personal information we collect including any disciplinary and grievance information. | We have a legitimate interest in doing so to provide a safe and fair environment for all candidates and to ensure the effective management of any disciplinary hearings, appeals and adjudications.We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
For criminal records history we process it on the basis of legal obligations or based on your explicit consent. |
For the purposes of equal opportunities monitoring | Name, title, date of birth, gender, information about your race or ethnicity, health and medical information data | We have a legitimate interest to promote an environment that is inclusive, fair and accessible.
We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. |
To enable Payroll services | All the personal information we collect | This is necessary to enable us to process timesheets and send payment to the payroll bureau/umbrella company/accountants. |
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a candidate or we may not be able to properly perform our agreement with you or comply with legal obligations.
For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our agreement with you.
Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place.
5. DIRECT MARKETING
Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about jobs, products and services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages. You can unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We share personal information with the following parties:
- Any party approved by you.
- Your employer.
- To any governing bodies or regional bodies for the profession that you have: to allow them to properly administer their organisation on a local, regional and national level.
- The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
- Your nominated Umbrella Company, Accountants and Payroll Bureau.
- We do not disclose personal information to anyone else except as set out above.
7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?
The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. In most cases if you have registered, but not been placed by us, then we would retain your details for 24 months since your last meaningful contact with us. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us. Exceptions to this rule are:
- Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for us.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.
You can update your information that we hold by contacting us using the details set out in the “Contacting us” section below.
9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information;
- the right to request that we transfer elements of your data either to you or another service provider; and
- the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.
If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
10. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
11. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please contact Nelly Hristeva, HR and Compliance Manager.
Contact Details:
A: Suite G01, Eagle House, 167 City Road, London, EC1V 1AW
E: nelly@ptl.agency
T: 0203 031 2766
Dated: 31 January 2023
Review date: 31 January 2024
Signed:
Martin Campbell
Managing Director