What this Notice covers
The HeadwayUK Ltd is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) and data protection legislation.
It applies to all clients and anyone agreeing to share their data with us.
Identity of the data controller
HeadwayUK 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 protection legislation to notify you of the information contained in this privacy notice.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Categories of personal data we process
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, email addresses
- Email correspondence
- Bank account details
- CCTV footage
- Information obtained through electronic means
- Information about your use of our information and communications systems
- Genetic information
- Information about business or company
Sources of personal data
We collect personal information about you through the process of communication or contracts or agreements of works, either directly from you or from background check provider. We may sometimes collect additional information from third parties including credit reference agencies.
We also collect additional personal information in the course of job-related activities throughout the period you are working for us.
Our lawful bases for processing your data
We will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we 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.
Our purposes for processing your data
- Making a decision about conducting business together
- Determining the terms on which you work with us
- 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
- Assessing qualifications for a particular job or task, including decisions about promotions
- Dealing with possible legal disputes involving you, or other employees, workers and contractors, including accidents at work
- Complying with health and safety obligations
- To prevent fraud
- 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
- Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information
Who has access to your data
We may share your personal information with third parties 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.
Recipients of your data may include third-party service providers other related business entities; a regulator or to otherwise comply with the law.
Where we do so, we will require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Security of your data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How we decide how long to retain your data
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have the right to:
- Request access to, and a copy of, your personal information
- Request correction of the personal information that we hold about you
- Request erasure of your personal information.
- 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.
If you believe we have not complied with your rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
If you do not provide personal data, it is likely to be impossible for the HeadwayUK Ltd to enter into, or to continue with, a working relationship with you.
Changes to this Privacy Notice
The HeadwayUK Ltd reserves the right to update this privacy notice at any time.