DATA PROTECTION PRIVACY NOTICE – September 2020
Welcome to Fingershield Safety (UK), c/o Cardea Solutions Privacy Notice, referred to in this document as “Fingershield Safety (UK), c/o Cardea Solutions”, “the Company” or “We”.
Here at Fingershield Safety (UK) we respect your privacy and are highly committed to protecting your personal data. When we refer to “your” personal data we are referring to you personally and, where it is applicable, to any individuals who are connected to your business, such as employees, consultants or workers, who you request that we process data for, in the provision of our services.
The General Data Protection Regulation (GDPR) is the latest EU data privacy and protection framework which is effective from 25th of May 2018.
We identify that the processing of such data is fundamental to the delivery of our services and commit to complying with data protection law which requires us to process personal data using the following principles;
It will be used lawfully and fairly;
It’s use, storage and removal will be transparent;
It will be collected for valid purposes that have been clearly explained to you and not used for other purposes, unknown to you;
It will be accurate and kept up to date;
It will be kept securely; and
It will only be kept for as long as is necessary.
We are committed to GDPR compliance and take our obligations seriously by building them into our day to day and strategic processes, some of which you want to consider when conducting your assessment from a GDPR point of view.
Fingershield Safety (UK) Data Protection Privacy Notice – Version 1 – January 2019
WHO TO CONTACT
This Policy sets out basic information; however, you may have specific questions or wish to exercise your legal rights.
We have set up a designated e-mail address for GDPR purposes, therefore, please use this or any of the contact details below;
If you believe that we have collected or processed your personal data incorrectly, you do have the right to make a complaint to the relevant body, the Information Commissioner’s Office (ICO) (www.ico.org.uk) However, we would appreciate the chance to deal with your concerns and so please contact us in the first instance.
WHAT IS “PERSONAL DATA”?
Personal data 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).
SPECIAL CATEGORIES OF PERSONAL DATA
There are also special categories of personal data as identified by GDPR which includes information relating to; racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership status, genetics, biometrics (for ID), physical or mental health, sexual life or sexual orientation and criminal activity, including alleged, proceedings, convictions or sentences.
In general, we do not collect any Special Categories of Personal Data about you, unless you are a Candidate or an Employee, in which case a separate Applicant Privacy Notice and an Employee Privacy Notice are available.
Fingershield Safety (UK) Protection Privacy Notice – Version 1 – January 2019
The collection and processing of this data is limited to the provision of services to our clients to enable us to provide payroll and HR advisory services and in fulfilling our contract with them.
WHEN DO WE COLLECT AND PROCESS PERSONAL DATA?
We may collect and process personal data in a variety of ways, the main ways are identified below and are examples, but this may not be an exhaustive list.
Interact with us directly via a telephone call, in-person discussion, networking event etc.
Visit our website or social media channels;
Sign up to our marketing mailing list;
Become a prospective client;
Become a client;
Apply for a work placement, work experience or job with us;
Become an Employee;
Work with us in a business relationship capacity such as a consultant, referrer, supplier or any other third party
KEEPING IT ACCURATE
In fulfilling our GDPR commitments, it’s important that the personal data we hold about you is accurate and up to date. As such, please keep us informed of any changes so that we can update our records and maintain our all-important relationship with you.
THE TYPES OF DATA WE COLLECT
We may collect, use, store and transfer a variety of personal data about you during our relationship with you.
We have attempted to group these together however, again this cannot be exhaustive;
Fingershield Safety (UK), c/o Cardea Solutions Protection Privacy Notice – Version 1 – September 2020
FAILING TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law or under the terms of a contract that we have with you, and you fail to provide the data when requested, we may not be able to perform the contract.
In such cases, having exhausted all avenues, we may be unable to start providing services or cancel the services however this will only occur following formal notification with an opportunity to rectify matters.
REASONS WHY WE USE YOUR PERSONAL DATA AND CONSENT
We will only use your Personal Data lawfully and most commonly when we need to perform the contract which we have entered into with you, where we need to comply with a legal or regulatory obligation or where it is necessary for our legitimate interests (and your interests do not override ours).
As such generally, except for some marketing activities, we do not rely upon consent as a legal basis for processing your Personal Data.
We believe that direct marketing and communication with current clients is a fundamental part of our contractual commitment as our “news” includes changes in the industry and so we rely on this legitimate interest to automatically put you on our mailing list, with the option for you to opt out at any time.
If you are not an existing client, we will ask you to opt in and therefore consent to receiving our marketing and communication information. The newsletter sign up section on our website clearly asks you to opt in to receiving marketing and communication from us.
We generally do not share your personal data with any other company for marketing purposes but in the unusual event that we do, we will obtain your express consent for this.
If you are on our mailing list, you have a clear and easy way to opt out at any time. If you opt out of marketing and communication with us, then we will continue to process your personal data in the provision of our services and your e-mail address will be retained, but not used, on our chosen online mailing software for record keeping purposes unless you specifically request for this to be deleted.
Our IT team have put together appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Our strategy on data security includes physical access controls, restriction of access to and encryption of data stored on automatically updated systems, protected by hardware and software firewalls, anti-malware solutions and multi-layered business continuity and disaster recovery strategies.
We have put in place procedures to deal with any suspected or actual data breach and will notify you where we are required to do so.
We will only retain your Personal Data, and that which belongs to individuals connected with your business, for as long as is necessary to fulfil our contract with you or for the purposes of satisfying a legal, accounting or regulatory requirement.
We assess retention on a case by case basis however; our minimum periods of retention for retaining personal data are;
For the entire period that you are a client or have a business relationship with us;
For two years after you have ceased being a client or having had a business relationship with us in which case all personal data will be deleted with the exception of basic information such as client name, services used, main contact name and contact details and any relevant information which we feel may be of mutual benefit in the future;
For 6 years plus, current year in the cases of financial or payroll information.
In the case of marketing and communications; we will retain and process this indefinitely until such time that you opt out.
In some cases, we may anonymise your personal data so that it can no longer be associated with you, for research or statistical purposes and we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have the right to;
Request Access to your personal data, commonly referred to as a data subject access request or DSAR which enables you to receive a copy of the personal
data we hold on you and to check that it is being lawfully processed;
Request Correction of your personal data which enables you to have any incomplete or inaccurate data corrected;
Request Erasure of your personal data. This allows you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. Please note that whilst we wish to comply with this as much as possible, it may be difficult to agree to this if we are required to continue processing for a legal reason(s); however we will notify you of this.
If you wish to exercise any of these rights, please contact us.