Privacy Policy
Our Privacy Policy
Last Updated February 2024
Data Protection Privacy Policy – Strand Hill Consulting Ltd
This Privacy Policy describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the retained EU law version of General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (“Data Protection Legislation”) as amended or updated from time to time.
Please read this Privacy Policy carefully to understand our policies regarding your information and how we will treat it. By using or accessing our website www.strandhill.co.uk (“Website”) or the services we offer (“Services”) you agree to the collection, use and disclosure of information in accordance with this Privacy Policy.
This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.
Strand Hill Consulting Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under Data ProtectionLegislation to notify you of the information contained in this Privacy Policy.
This Privacy Policy applies to current and former employees, workers, contractors, candidates and individuals at clients or potential clients of ours in respect of whom we hold personal data. This Privacy Policy does not form part of any contract of employment, a contract to provide services or any other contract. We may update this Privacy Policy at any time.
Data protection principles
We will comply with Data Protection Legislation. In accordance with Data Protection Legislation, we will:
Process personal data lawfully, fairly, and transparently, and only for specified and legitimate purposes
Collect and use personal data only to the extent necessary for the purposes for which it was collected
Inform individuals of the data sharing practices through clear and concise privacy notices. These notices will include the purpose of data sharing, the categories of recipients, and any applicable safeguards in place
Only share the minimum amount of personal data necessary to achieve the intended purpose. Unnecessary or excessive data sharing will be avoided.
Keep personal data accurate, complete, and up-to-date, and take appropriate measures to rectify or erase any inaccurate or outdated data
Implement robust security measures to ensure the confidentiality, integrity, and availability of shared personal data. Access controls, encryption, and other technical safeguards will be employed to prevent unauthorised access or disclosure
Keep information only as long as necessary for the purposes we have told you about
Implement appropriate technical and organisational measures to ensure the security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage
Provide appropriate training and guidance to our employees on data protection and ensure they are aware of their responsibilities
Obtain appropriate consent from individuals where necessary and ensure they are informed of their rights under data protection laws
Provide individuals with access to their personal data upon request, and facilitate the exercise of their other rights under data protection laws
Regularly review and evaluate our data protection practices and procedures to ensure their ongoing suitability, adequacy, and effectiveness
The kind of information we may hold about you
Personal data, or personal 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).
Depending on the circumstances, we may collect, store, and use the following categories of personal information about you:
Personal contact details such as name, username or similar identifier, title, addresses, telephone numbers, and email addresses
Date of birth
Gender
Marital status and dependants
Next of kin and emergency contact information
National Insurance number
Bank account details, payroll records and tax status information
Salary, annual leave, pension and benefits information
Start date(s) of job roles
Location of employment or workplace
Copy of identity documents, such as passport, driving licence and utility bills
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
Employment records (including job titles, work history, working hours, training records and professional memberships)
Salary/payments history
Performance information
Disciplinary and grievance information
CCTV footage and other information obtained electronically, such as telephone recordings, email usage data, internet usage data and swipe card records
Photographs
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Cookies Data; like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites.
Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
Special Categories
We may also collect, store and use the following “Special Categories” of more sensitive personal information:
Where we do collect “Special Categories” of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and it is necessary to do so for our business, we will obtain your specific consent, unless we have another lawful basis to do so.
We may process special categories of personal information in the following circumstances:
Where we need to carry out our legal obligations or exercise specific rights (either yours or ours) related to employment and in line with our data protection policy
Where it is needed in the public interest, such as for equal opportunities monitoring, in relation to our occupational pension scheme, and in line with our data protection policy
Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards
In limited circumstances, with your explicit written consent
We may also use special categories of personal information in the following ways:
We may use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
We may 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 may 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.
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 members or former members in the course of legitimate business activities with the appropriate safeguards.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
How may your personal information be collected?
We may collect personal information about employees, workers, contractors, candidates, clients and individuals at clients or potential clients of ours in a number of different ways. This includes:
An application and recruitment process, either directly from candidates or sometimes from another employment agency, employment business or background check provider.
We may sometimes collect information from third parties including former employers, credit reference agencies or other background check agencies.
Individuals at clients may provide us with their contact details as part of a discussion about our services.
We may also collect personal data which is publicly available on websites such as:
Jobs boards
LinkedIn, or similar recruitment-related websites.
We may use third-party applications which source their data from publicly-available websites.
We may also collect additional personal information in the course of job-related activities throughout the period of you working for us or where you undertake a placement.
How we may use information about you
We will only use your personal information when the law allows us to. Most commonly, we may use your personal information in the following circumstances:
Taking steps, at your request, to represent you for employment purposes
Where we need to perform a contract which we have entered into with you
The need to comply with a legal obligation
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
We may also use your personal information in the following situations, which are likely to be rare:
Where it is necessary to protect the vital interests of you or another person
Where it is needed in the public interest or for official purposes
Situations in which we may use your personal information
We may need the categories of information (points mentioned in the section ‘The kind of information we hold about you’) for the reasons set out above (‘How we may use information about you’). Primarily this will be where we are taking steps at your request to represent you for employment purposes and/or entering into a contract we have entered into with you (or your employer or a company related to you). 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.
The situations in which we may process your personal information are listed below. The list below indicates the categories of data which may be involved in processing your personal information (depending on the circumstances).
Making a decision about your recruitment or appointment
Determining or agreeing with you (or your employer or a company related to you) the terms on which we work together
Checking you are legally entitled to work in the UK
Paying you and, if you are an employee, deducting tax and National Insurance contributions
Providing contractual benefits to you
Liaising with your pension provider
Administering the contract we have entered into with you
Business management and planning, including accounting and auditing
Conducting performance reviews, managing performance and determining performance requirements
Making decisions about salary reviews and compensation
To assess your suitability for potential roles with clients
To contact you about a potential role with a client
To contact you about your service requirements
To propose a candidate for engagement (on a temporary or permanent employment basis) by your employer
Conducting a credit check on you prior to you commencing work for a client
Assessing qualifications for a particular job or task, including decisions about promotions
Gathering evidence for possible grievance or disciplinary hearings
Making decisions about your continued employment or engagement
Making arrangements for the termination of our working relationship
Education, training and development requirements
Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work
Ascertaining your fitness to work
Managing sickness absence
Complying with health and safety obligations
To prevent fraud
Equal opportunities monitoring
To contact you with information about our services
To monitor your use of our information and communication systems to ensure compliance with our IT policies
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
To conduct data analytics studies to review and better understand employee retention and attrition rates
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Failure to provide personal 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 representing you for employment, paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Changes of purpose
We will only use your personal information for the purposes for which we collected it; to fulfil your order and to receive our services. We will only not use your information for the purposes of which we collected it, if we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may process your personal information without your knowledge or consent where this is required or permitted by law.
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 envisage that we may hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. 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 may use information about criminal convictions and offences in the following ways:
To consider your suitability for a role with clients or with us
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in any of the following circumstances:
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights
Where we have notified you of the decision and given you 21 days to request a reconsideration
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights
If we make an automated decision on the basis of any special category data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions which have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.
Sharing information with third parties
We may share your personal information with third parties where required by law, where it is necessary to operate the working relationship with you or where we have another legitimate interest in doing so.
“Third parties” includes UK third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services, and recruitment services.
We may share your personal information with other entities in our group and may contract with third parties to supply services to you on our behalf. This is as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data, payment processing, search engine facilities, advertising and marketing or where we consider that another group entity is better placed to consider your suitability for a potential role. In some cases, the third parties may require access to some or all of your data. These are the third parties that may have access to your information:
Bullhorn, Inc
Brendan P Byrne & Co Limited (BPB Accountants)
National Employment Savings Trust (NEST Pensions)
Quba Solutions Ltd
Paystream My Max Ltd
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.
All our third-party service providers and other entities in the group are also required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at info@strandhill.co.uk
Data retention
How long will you use my information for?
Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes of which the personal data is used for.
Key points related to the duration of data retention under the UK GDPR include:
Purpose Limitation:
Personal data should only be processed for the specific purposes for which it was collected. Once those purposes are fulfilled, the data should not be kept any longer.
Archiving and Research Exceptions:
While the general rule is to delete or anonymise personal data after the original purpose is fulfilled, there are exceptions for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes. However, safeguards will be in place to protect the rights and freedoms of data subjects.
Implementing Technical and Organisational Measures:
Organisations are required to implement appropriate technical and organisational measures to ensure that personal data is kept securely during any extended retention period.
Review and Purge Processes:
We will establish processes to regularly review the necessity of retaining personal data and will delete or anonymise it when it is no longer needed for the original purpose.
Your rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, in accordance with Data Protection Legislation, 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.
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
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please write to us.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
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. To withdraw your consent, please email us at info@strandhill.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this Privacy Policy
This Privacy Policy will be regularly reviewed and updated to ensure compliance with all applicable Data Protection Laws. The success of this policy depends on the active participation and cooperation of all employees.
If you have any questions about this Privacy Policy, please contact us at info@strandhill.co.uk