Client Focus Purpose To promote a consistently high level of relationship with Elizabeth Michael Associates’ (EM) clients by focussing on their needs. To provide excellence in customer service that enables superior business performance for both EM and our partners. Scope This policy is applicable to all direct employees working under a Contract of Employment. A summary version is posted on the EM website for the information of all stakeholders. NB. This policy does not concern itself directly with competitive tendering or any new business winning strategy. Policy Statement EM seeks to achieve the business objective of excellence in client relations in a number of ways. We consider our total approach to client service to be a source of competitive advantage and therefore commercially sensitive information that will not be fully disclosed in the public arena. Our business objectives and organisational values are best achieved in an environment of mutual trust and respect, where our people can each rely on one another for support and to do the right thing. EMA strives to promote a challenging yet supportive work culture that encourages personal responsibility, self discipline and opportunity. We believe that this approach to engaging our people provides the rock on which we can build a client focussed culture. Procedure EM uses a number of tools and methodologies to guide in the achievement of excellent client relationships. We are happy to discuss these with clients on request. The headlines of our approach are as follows: We are sensitive to the general business environment and community in which our clients operate We differentiate clients and understand their uniqueness We listen to our clients We inspire trust through honesty, decency and integrity, The Elizabeth Michael Way” We act on client and candidate feedback, responding in a timely and helpful manner, escalating where appropriate and learning from it We build long term relationships in which our consultancy approach can add even greater value We respect the confidentiality of our clients’ business and information We provide value for money We deliver in the following ways: Through our processes, which are focussed on delivering to our clients Through the design of our business, organised to deliver results Through our culture and values Through our brand promise, “The Elizabeth Michael Way” Through our peoples’ skills and behaviours Feedback We welcome feedback from our clients on our current services and indeed where there may be new services that our clients desire. Clients are invited to share with us their experience of our service and any suggestions as to how we may deliver to even higher standards. Responsibility All those persons referred to within the scope of this policy are required to adhere to its terms and conditions. Management are responsible for ensuring that this policy is applied within their area. Occasionally EM clients have service or delivery issues that are not managed to the client’s satisfaction. The EM consultant responsible is expected to take personal accountability to clarify the precise nature of the service or delivery short fall and to discuss potential redress with the client. Where the matter is not resolved to the client’s satisfaction, escalation to the MD of EMA is required within 24 hours of the client’s response. At the MD’s discretion the client may be asked to put their complaint in writing at this stage, if it is not already.
Code of Conduct Purpose To provide a Code of Conduct that must be followed by Elizabeth Michael’s employees without exception. Rather than providing an exhaustive list, the policy aims to provide a substantial number of rules which will set the standard of conduct required by Elizabeth Michael (EM). Scope All employees who work under a Contract of Employment and all associated persons such as contractors, consultants and others engaged under a Contract for Service. The Code of Conduct applies whilst these persons are on site and off site and whilst representing EM during or outside working hours. They do not normally apply at other times. Certain rules also apply to visitors and all other persons involved with work for or on behalf of EM. Where this applies, separate instructions will be given. Policy Statement EM strives to promote a challenging yet supportive work culture that encourages personal responsibility, self discipline and opportunity. Our business objectives and organisational values are best achieved in an environment of mutual trust and respect, where we can each rely on one another for support and to do the right thing. Our philosophy is that people want to come to work, are motivated to contribute and have a desire to be successful. In a small business like EM, opportunities exist for people to just get on with the job without unnecessary bureaucracy. However it is important to underpin this commitment with a framework of policy. The rules contained within the Code of Conduct are designed to promote legal compliance, fairness, consistency, order and superior performance within EM. Many of these rules are not new, being already in the Staff Handbook. The manner in which they are applied can only be determined by reference to the Performance Management and Disciplinary policies. The Code of Conduct does not refer to every situation which may arise; instead it is intended to provide a number of important examples which reflect the standards of behaviour required by EM. It is therefore important that all employees read and understand them in order to appreciate the general standard of conduct which is required. If any employee has any doubt about the meaning of a rule; they must ask for clarification during their induction training or from their immediate manager or HR Consultant. EM will take all reasonable steps to ensure that all individuals are made aware of the contents of this policy. If an employee breaches any aspect of the Code of Conduct policy, an investigation will be initiated. This may result in a disciplinary hearing, which could lead to summary dismissal on the grounds of gross misconduct under the Disciplinary policy. All employees and other associated persons must: Comply with Company rules, instructions, procedures and contractual agreements during their employment with the Company and follow all reasonable instructions given by those supervising or managing their activities and areas of work. Seek to maximise their involvement in their job and to strive for superior performance in every aspect of our operation. Accept opportunities that arise to develop their breadth and depth of expertise and take ownership for personal development. Comply, as a minimum standard, with the normal hours of work or those specifically applicable to that individual and not be absent without permission. Be flexible in terms of duties undertaken and hours of work to sustain the EM business as a whole and to support colleagues. Report to their manager any loss or damage to personal or organisation property and any accident, injury or potentially dangerous occurrence at work. Inform their immediate manager when they are unable to come to work, in accordance with the Absence Reporting procedure and supply appropriate documentation. Co-operate to ensure the safety and security of EM’s employees, premises and property, including information. Treat clients, candidates and work colleagues in a courteous and professional manner. Present them self in a professional and business-like manner when representing the Company and maintain their working area, documentation and records in an orderly fashion. Return all property belonging to the Company upon termination of employment. Comply at all times with EM’s Telephone, E – Mail and Internet policy, which includes all policies / guidelines relating to any technology / equipment usage. Comply with the requirements of the Data Protection Act and maintain absolute confidentiality with regard to EM owned / managed information and records or data collected and used in the course of work. Employees who are required to work from home must obtain authorisation from their manager as to all articles which can be retained at home for the purpose of fulfilling their role. All employees and other associated individuals must not: Commit any act which may endanger persons or property or which breaches any safety rule, Company policy or legislation. Use EM property or any other property on EM premises, for any other purpose other than that for which it is intended and for which they have authorisation. Remove any article or articles which are EM property, or any individual’s property, kept on EM’s premises without authorisation from their manager. Discriminate unfairly between employees, clients or candidates on the grounds of their race, creed, colour, nationality, ethnic origins, age, disability, sex, marital status, family circumstances or sexual orientation. Engage in any form of physical or verbal abuse, threatening behaviour, harassment or bullying. Behave in a way that disrupts colleagues, is detrimental to business performance or in any way discredits EM as a professional working environment. Falsify records, expenses or defraud EM in any manner. Accept gifts or gratuities which may be considered to be bribes. Report to work, or be at work, unfit due to the influence of alcohol, or other drugs or substances. Leave work without permission. Carry out private trading on organisation premises without permission from their manager. Distribute private literature or make any collections for charities without authorisation from their manager. Bring or encourage non business visitors onto EM premises without the specific authorisation of the management. Carry out any business or employment which is unconnected with EM during or outside working hours without express permission. These rules are not exhaustive and may be amended as necessary. Responsibility All those persons referred to within the scope of this policy are required to adhere to its terms and conditions. Management are responsible for ensuring that this policy is applied within their area.
Purpose To inform of Elizabeth Michael’s (EM) responsibilities for equal opportunities and our commitment to promoting diversity at work and in the wider community. To ensure that EM can attract, retain and build superior relationships with employees, candidates, clients and other stakeholders in our community regardless of individual differences, promoting social and economic inclusivity. Scope This policy applies to all job applicants, employees, contractors/consultants and any other employee or person acting on behalf of EM who is concerned with the employment or engagement, or potential employment or engagement of people. As and when EM sub contracts work to another recruitment consultancy it will be a requirement of the supplier to operate within the terms of this policy. The primary focus of this policy is the employment relationship. The nature of EM’s business demands that the best practice described extends to the recruitment and selection process of permanent and temporary agency staff and our impacts in the wider community. Policy Statement It is crucially important to value all people as individuals and to concentrate on personal abilities and strengths in order to gain organisational benefit from diversity. EM strives to employ a workforce that is representative of the community in which we operate. Equal opportunity describes the position where all people have equality of access to opportunity. Groups who experience discrimination are identified and receive protection in law. All employers and employees are obliged to comply with the law. Diversity describes the approach whereby the focus is on developing a culture that is accepting of individual difference, regardless of whether or not the individuals concerned are covered by equal opportunities legislation. It is the philosophy of EM that our business goals are best achieved by a committed team working together in an environment of trust and mutual respect. This is our business DNA that permeates through all our employment policies and behaviours, embodied in “The Elizabeth Michael Way”. Specifically EM embraces diversity and will seek to promote the benefits of diversity in all of our business activities. We will seek to develop a business culture that reflects that belief. We will seek to widen the media in which we recruit to ensure as diverse an employee and candidate base as possible. We will strive to make sure that our clients meet their own diversity targets. EM is committed to diversity and will promote diversity for all employees, workers and applicants and shall adhere to such a policy at all times. We will review on an on-going basis all aspects of recruitment to avoid unlawful or undesirable discrimination. EM will treat everyone equally irrespective of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or membership or non-membership of a Trade Union or spent convictions, and places an obligation upon all staff to respect and act in accordance with the policy. EM is committed to providing training for its entire staff in equal opportunities practice. EM shall not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. EM will ensure that each candidate is assessed only in accordance with the candidate’s merits, qualifications and abilities to perform the relevant duties required by the particular vacancy. EM will not accept instructions from clients that indicate an intention to discriminate unlawfully. We at EM aim to embrace diversity; we seek to be as diverse as the community we serve and are proud of the cultural diversity of our work force. As a socially aware company we seek to develop a business culture that enables this objective. Communication The Equality and Diversity Policy is available to all stakeholders, both in hard copy and on the Elizabeth Michael web site. If alternative formats of the Policy are required, please contact the HR Consultant. EM will, from time to time, supplement policy with codes of practice or guidelines on behaviour and these will be disseminated to the relevant members of staff. Further policy is available dealing with the different strands of potential discrimination. Implementation The HR Consultant will review on an on-going basis all aspects of our recruitment process to develop our company policies in line with the ever-changing society in which we do business as to avoid unlawful or undesirable discrimination. In order to improve our workforce our diversity policy is implemented throughout all areas of our organization. We will provide appropriate training to our direct employees and collect and check data provided in order to monitor the performance of this policy. Any complaint will be taken seriously and dealt with in a timely and sensitive manner, in accordance with the appropriate grievance and disciplinary procedure. Responsibility EM requires all stakeholders to recognize individual rights and to respect these rights in their everyday dealings with other stakeholders. All employees, candidates, temporary staff, clients and other stakeholders have a duty to support and uphold the principles contained in this Equality and Diversity Policy and supporting policies. The commitment of all stakeholders is required to make the policy a success.
Purpose To inform on our objective to deliver a superior service to our stakeholders that is business focused, sustainable and committed to improving our environmental performance. Scope This policy is applicable to all direct employees working under a Contract of Employment. A summary version is posted on the Elizabeth Michael (EM) website for the information of all stakeholders. Policy Statement EM seeks to achieve service excellence in all aspects of our work. We conduct our business in an ethical way, taking account of the impact we have economically, socially, environmental and in terms of human rights. We abide by environmental legislation and seek to improve our environmental performance, specifically by defining those areas in which we can make a difference, setting targets and measuring what we achieve. We believe that doing the right thing, and working with like minded people delivers significant benefits, not only to EM and our immediate connections, but also in the wider community. Procedure EM has identified the following key environmental areas where we can make a difference Consumption of resources Energy Transport Education Procurement We deliver in the following ways Consumption of resources and energy We work with our clients and temporary staff to migrate all job applications, timesheets, payslips and invoices to an electronic base, minimising printing costs and paper usage. We conduct most written communication by e mail. This also impacts on the transport dimension, as our reliance on the postal delivery service is minimised We seek to reduce waste. For example, we get things right first time and reuse non confidential waste paper where possible and shred confidential waste We discourage the printing of documents unless it is absolutely necessary. When we do print we use efficiency options where possible such as two sided copying We turn off, hibernate or stand by equipment such as PCs and photocopier when not in use We manage our use of independent environmental controls such as heating and air conditioning. We turn off unnecessary lighting We seek to reduce our consumption of energy in real terms year on year through monitoring, effective management and power efficient appliances We recycle our computer equipment in a responsible way, cleansing of data and providing to schools or charities. Where disposal is the only option we do this through an authorised third party contractor We recycle mobile phones, print cartridges and all consumables that have recycling potential Transport We use a small low emission, fuel efficient vehicle to attend client meetings and take great care in planning client visits and diary management to avoid, where possible, single person or single purpose journeys We identify public transport connections to our office and client sites and inform our candidates and temporary staff accordingly We minimise transport impacts through telephone interviews where practicable Education We aim to encourage and support environmental initiatives in our adopted school We make all our employees aware of our environmental objectives and encourage their commitment in making things happen We build awareness with our suppliers, clients and other stakeholders as to our environmental values Procurement At EM we have a local focus and support people and businesses in our community. Our policy is to procure goods and services from neighbouring organisations that share our environmental values Our procurement decisions are based on price, quality, service and environmental factors We buy, wherever practicable, goods from sustainable sources or recycled material Responsibility All those persons referred to within the scope of this policy are required to adhere to its terms and conditions. Management are responsible for ensuring that this policy is applied within their area. Environmental performance measurement is the responsibility of the Managing Director.
Introduction Thank you for choosing Elizabeth Michael Associates (EM) to support you in the next step of your career. At EM, we understand that work is important to people and we aim to provide quality opportunities for candidates who want to be successful. We are proud to work with many excellent employers who in turn wish to attract talented candidates who are right for their business. We help make this happen. The beliefs we hold are at the heart of the relationship that we foster with our candidates. This rapport enables us to represent your interests in a positive and honest way with our clients. This document is designed to inform candidates of the Elizabeth Michael Way. This is the phrase we use to describe, amongst other things, our commitments to and expectations of candidates, our values, the way we do business and how candidates can give feedback. A copy of this charter is posted on the Elizabeth Michael Associates web site. Scope This charter applies to all candidates regardless of the nature of work they are seeking. Whilst we use the word candidate predominantly in this charter, the scope includes temporary workers. All Elizabeth Michael Associates are expected to abide by the Candidate Charter. Candidates and temporary workers therefore should expect to be treated in accordance with the Elizabeth Michael Way. The Elizabeth Michael Way The Elizabeth Michael Way encapsulates our culture, our behaviour and the things we believe in. EM people are encouraged to adopt the EM way in their everyday encounters with clients, candidates and each other, as well as with all other stakeholders in the business. We are passionate about our business. It is more than just a job; it’s a way of life We inspire trust through honesty, decency and integrity We are both supportive and challenging We believe that work is important to people, people are important to our clients and our clients are important to us We shape great fits between candidates and clients, promoting success for all We have a local focus, supporting local people in our community and businesses We are a consultancy; we listen to our clients and candidates and work in partnerships We strive for superior performance We have a no-blame culture, learning from mistakes, building knowledge from successes We take pride in being a winning team We have fun doing serious things. What candidates and Elizabeth Michael Associates should expect from each other Equality of treatment It is crucially important to value all people as individuals and to concentrate on personal abilities and strengths. EM strives to promote employment of a workforce that is representative of the community in which we operate, encouraging selection on the ability to do a job. Respect In all transactions EM Associates are required to treat people with respect and have an expectation of reciprocation. Honesty EM will obtain as much information as possible about our clients and the opportunities they have available. We will share information with candidates as agreed with our clients. Candidates are required to provide all information required by EM in a timely and honest way. This includes accurate completion of required EM paperwork, any evidence of work or periods of not working, reference details, evidence of qualification, driving licence and eligibility to work in the UK. Information provided by a candidate in interview with an Associate of EM is considered to be as binding as any written assurance. Objectivity EM are in a position where they can offer advice to both clients and candidates in an attempt to create a great fit. We will look for evidence in the candidate’s history, carry out tests and conduct an interview to assess the fit between the candidate and the client’s requirements. Where there is a gap between the client’s expectations and the candidate’s capabilities we may be able to help the candidate close the gap, or ask the client to reconsider whether certain requirements are essential to their selection process. Sometimes a candidate might have aspirations that can not be met. We can not always place people in jobs and we will always try to explain why. Discretion and confidentiality We will respect your personal data, processing and retaining or destroying in accordance with the Data Protection Act. We will ask you to specify any organisations that you do not wish your details to be sent to. In the course of discussions with clients a candidate may become privy to business sensitive information. EMA expects candidates to respect the clients’ business interests. Feedback EM encourages candidates and temporary workers to provide feedback about their experiences of working with EM, or on any matter whatsoever. EM uses feedback to continuously improve the service we provide. Support and guidance EM will keep in contact with candidates during the recruitment process and beyond, where the candidate secures a position. One size does not fit all and we will tailor our support, within reason, to the needs of the candidate. On occasions a candidate may not demonstrate sufficient commercial awareness, lack interview experience or need a basic skill sharpening up. We will try to help. Prompt resolution Where confusion or difficulties arise, candidates are requested to telephone EM with details for accountable Associate, who will investigate and respond within 4 working hours. Payroll queries are normally resolved immediately, provided EM have received the correct information required from the worker concerned. Other issues may take a little longer but we will always respond at the earliest possible opportunity. Where a query is made by EM of a candidate or temporary worker, wherever possible, a similar response time would be appreciated. Where a candidate or temporary worker is in any way unhappy with the service they have received from EM or a client they may speak to the Managing Director of EM outlining the nature of their dissatisfaction. At this stage they may be requested to put their comments in writing, if they have not already done so. EM want candidates to be happy and will always investigate and give a response within 3 working days. Responsibility All those persons referred to within the scope of this charter are required to adhere to its terms and conditions. Management are responsible for ensuring that this charter is applied within their area.
Company Name: Elizabeth Michael Associates Ltd (‘the Company’) Company Contact details: Sally Hosken – Controllers Representative - firstname.lastname@example.org Samantha Hodgson – Controllers representative – email@example.com Jessica White – Controllers representative – firstname.lastname@example.org Hannah Morgan – Controllers representative – email@example.com Zachary Mairura – Controllers representative – firstname.lastname@example.org Helen Wicks – Controllers representative – email@example.com Olivia Hyde – Controllers representative – firstname.lastname@example.org Claire Wakeling – Controllers representative – email@example.com Alexandria Edwards – Controllers representative – firstname.lastname@example.org Georgina Tansur – Controllers representative – email@example.com All can be reached on 0115 9799806 Document DP5A Privacy Notice (when personal data is obtained from the data subject) Topic: Data protection Date: April Version: 0006 The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement. Collection and use of personal data Purpose of processing and legal basis The Company has collected your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are: Consent Legitimate interest Legal obligation Contractual obligation Legitimate interest Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows: For the Company to provide you with work-finding services. For the Company to process with or transfer your personal data to their client/s in order to provide you with work-finding services. For the Company to process your data on a computerised database provided by Adapt in order to provide me with work-finding services. Bank Details (Temporary Worker Only) in order that your salary can be paid directly to your bank account Recipient/s of data The Company will process your personal data with the following recipients: Clients in order to provide work-finding purposes The company’s bank in order that salary can be paid directly into your bank account (Temporary workers only) Statutory/contractual requirement Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are: Withdrawal of any employment offer Data retention The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time. The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. Where the Company has obtained your consent to process your personal data and sensitive personal data we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data. Your rights Please be aware that you have the following data protection rights: The right to be informed about the personal data the Company processes on you; The right of access to the personal data the Company processes on you; The right to rectification of your personal data; The right to erasure of your personal data in certain circumstances; The right to restrict processing of your personal data; The right to data portability in certain circumstances; The right to object to the processing of your personal data that was based on a public or legitimate interest; The right not to be subjected to automated decision making and profiling; and The right to withdraw consent at any time. Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Sally Hosken – firstname.lastname@example.org where applicable, or any representative of the controller as listed above Complaints or queries If you wish to complain about this privacy notice or any of the procedures set out in it please contact: The Data Controller, Sally Hosken – email@example.com or any representative of the controller as listed above You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.
Company Name: Elizabeth Michael Associates Ltd Document DP3 Data Protection Policy Topic: Data protection Date: April Version: 0006 Contents Introduction Definitions Data processing under the Data Protection Laws The data protection principles Legal bases for processing Privacy by design and by default Rights of the Individual Privacy notices Subject access requests Rectification Erasure Restriction of processing Data portability Object to processing Enforcement of rights Automated decision making Personal data breaches Personal data breaches where the Company is the data controller Personal data breaches where the Company is the data processor Communicating personal data breaches to individuals The Human Rights Act 1998 Complaints Appendix Annex – legal bases for processing personal data Introduction All organisations that process personal data are required to comply with data protection legislation. This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’). The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data. As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data. This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure. Definitions In this policy the following terms have the following meanings: ‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her; ‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data; ‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller; ‘personal data’* means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data; ‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements; ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual; ‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions. * For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data. ‘Supervisory authority’ means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO). All of these definitions are italicised throughout this policy to remind the reader that they are defined terms. The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z616548X The Company may hold personal data on individuals for the following purposes: Staff administration; Advertising, marketing and public relations Accounts and records; Administration and processing of work-seekers’ personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support; Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers; Administration and processing of clients’ personal data for the purposes of verifying references The data protection principles The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is: Processed lawfully, fairly and in a transparent manner; Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes; Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; Kept for no longer than is necessary for the purposes for which the personal data are processed; Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that The data controller shall be responsible for, and be able to demonstrate, compliance with the principles. Legal bases for processing The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws. The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this. Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer. Privacy by design and by default The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as: data minimisation (i.e. not keeping data for longer than is necessary); pseudonymisation; anonymization;] cyber security; Rights of the Individual The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual. Privacy notices Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data. Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month. If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner). Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing. Subject access requests The individual is entitled to access their personal data on request from the data controller. Rectification The individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual. If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred. Erasure The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data. If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date. If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation. If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred. Restriction of processing The individual or a data controller at the individual’s request, has the right to ask the Company to restrict its processing of an individual’s personal data where: The individual challenges the accuracy of the personal data; The processing is unlawful and the individual opposes its erasure; The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual. If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred. Data portability The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where: The processing is based on the individual’s consent or a contract; and The processing is carried out by automated means. Where feasible, the Company will send the personal data to a named third party on the individual’s request. Object to processing The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest. The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims. The individual has the right to object to their personal data for direct marketing. Enforcement of rights All requests regarding individual rights should be sent to the person whose details are listed in the Appendix. The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests. Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved. Automated decision making The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision: Is necessary for the entering into or performance of a contract between the data controller and the individual; Is authorised by law; or The individual has given their explicit consent. The Company will not carry out any automated decision-making or profiling using the personal data of a child. Personal Data Breaches All data breaches should be referred to the persons whose details are listed in the Appendix. Personal data breaches where the Company is the data controller: Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO. Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction. Personal data breaches where the Company is the data processor: The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach. Communicating personal data breaches to individuals Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay. The Company will not be required to tell individuals about the personal data breach where: The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption. The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise. It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals. Human Rights Act 1998 All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times: Right to respect for private and family life (Article 8). Freedom of thought, belief and religion (Article 9). Freedom of expression (Article 10). Freedom of assembly and association (Article 11). Protection from discrimination in respect of rights and freedoms under the HRA (Article 14). Complaints If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy. Alternatively you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/ Appendix List names of those responsible for: adding, amending or deleting personal data; responding to subject access requests/requests for rectification, erasure, restriction data portability, objection and automated decision making processes and profiling; reporting data breaches/dealing with complaints; Sally Hosken – Data Controller - firstname.lastname@example.org Samantha Hodgson – Controllers representative – email@example.com Jessica White – Controllers representative – firstname.lastname@example.org Hannah Morgan – Controllers representative – email@example.com Zachary Mairura – Controllers representative – firstname.lastname@example.org Helen Wicks – Controllers representative – email@example.com Olivia Hyde – Controllers representative – firstname.lastname@example.org Claire Wakeling – Controllers representative – email@example.com Alexandria Edwards – Controllers representative – firstname.lastname@example.org Georgina Tansur – Controllers representative – email@example.com All can be reached on 0115 9799806