Data controller: The People’s Partner Ltd, Michelle Raymond
Data Protection Lead: Ms Audrey Limery
The People’s Partner Ltd collects and processes personal information, or personal data, relating to its clients, web visitors and customers who purchased something from our store or downloaded a free product. This personal information may be held by the People’s Partner Ltd on paper or in electronic format.
The People’s Partner Ltd is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information both during and after your working relationship with The People’s Partner. We are required under the GDPR to notify you of the information contained in this privacy notice.
The People’s Partner Ltd has appointed data protection lead to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact Audrey Limery, email@example.com
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national and European laws and requirements for user privacy.
What types of personal information do we collect about you?
Personal information is any information about an individual from which that person can be directly or indirectly identified. It doesn’t include anonymised data, i.e. where all identifying particulars have been removed.
The People’s Partner Ltd collects, uses and processes personal information about you. This includes:
- your contact details, including your name, address, telephone number and personal e-mail address
HR Clients only
- your emergency contact details/next of kin
- your date of birth
- recruitment records, including personal information included in a CV, cover letter, interview notes, references, copies of proof of right to work in the UK documentation, copies of qualification certificates, copy of driving licence and other background check documentation
- your bank account details, payroll records, tax code and tax status information
- any disciplinary, grievance and capability records, including investigation reports, collated evidence, minutes of hearings and appeal hearings, warning letters, performance improvement plans and related correspondence
- training records
The People’s Partner Ltd may also collect, use and process the following special categories of your personal information (only applicable for HR paid clients):
- information about your health, including any medical condition, whether you have a disability in respect of which the People’s Partner Ltd needs to make reasonable adjustments, sickness absence records (including details of the reasons for sickness absence being taken), medical reports and related correspondence
- information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation
- trade union membership
- information about criminal convictions and offences.
How do we collect your personal information?
The People’s Partner may collect personal information about you in a variety of ways. It is collected during a download of a product on our website, through an event where you provided us with your contact details, by email, by Whats App or Facebook Messenger.
Whilst some of the personal information you provide us has a legitimate business interest so that we can continue to keep you updated with new products and services, some of it you may be asked to provide to us on a voluntary basis. We will inform you whether you are required to provide certain personal information to us or if you have a choice in this.
Your personal information may be stored in different places, a locked filing cabinet, the People’s Partner Ltd’s management system and in other IT systems, such as the e-mail system that is encrypted and password protected.
Why and how do we use your personal information?
We will use your personal information in one or more of the following circumstances:
- where we wish to update you with products and services
- where we need to comply with a legal obligation (Paid HR Clients only)
- where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests.
We need all the types of personal information listed under “What types of personal information do we collect about you?” primarily to enable us to perform our contract with you and to enable us to comply with our business obligations. In some cases, we may also use your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include: performing or exercising our obligations or rights under the direct relationship that exists between the People’s Partner Ltd and you as its client (HR Clients only).
The purposes for which we are processing, or will process, your personal information are to:
- enable us to maintain accurate and up-to-date customer/client records
- to provide you with only the information you need
- to tailor our products to your exact requirements
Please note that we will never process your personal information without your consent.
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, or sign up to our People’s Partner Ltd, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no. If after you opt-in, you change your mind, you may withdraw your consent at any time.
What if I fail to provide personal information?
If you fail to provide certain personal information when requested or required, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights (Paid HR clients only)
Why and how do we use your sensitive personal information?
Where the People’s Partner Ltd processes other special categories of personal information, i.e. information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation, this is done only for the purpose of equal opportunities monitoring and in line with our data protection policy. Personal information that the People’s Partner Ltd uses for these purposes is either anonymised or is collected with your explicit written consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.
We may also occasionally use your special categories of personal information, and information about any criminal convictions and offences, where it is needed for the establishment, exercise or defence of legal claims. (Paid HR clients only).
Change of purpose
We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain the legal basis which allows us to process your personal information for the new purpose and we will provide you with any relevant further information. We may also issue a new privacy notice to you. (Paid HR clients only).
Who has access to your personal information – Paid HR clients only.
Your personal information may be shared internally within the People’s Partner Ltd, including with members of the marketing team.
The People’s Partner Ltd may also share your personal information with third-party service providers (and their designated agents), including:
- external IT services such as Breathe HR software https://www.breathehr.com/privacy-policy/
- external auditors
- professional advisers, such as lawyers and accountants
We may also need to share your personal information with a regulator or to otherwise comply with the law.
We may share your personal information with third parties where it is necessary to administer the contract we have entered into with you, where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party).
How does the People’s Partner Ltd protect your personal information?
The People’s Partner Ltd has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those designated staff and other third parties who have a business need to know in order to perform their job duties and responsibilities.
Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with our written instructions and we do not allow them to use your personal information for their own purposes.
The People’s Partner Ltd also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
For how long does the People’s Partner Ltd keep your personal information?
The People’s Partner Ltd will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal or accounting requirements.
The People’s Partner Ltd will generally hold your personal information for the duration of your engagement but data will be minimised.
Once you have left your engagement has been terminated, we will generally hold your personal information for one year after the termination of your employment or engagement (for paid HR and Coaching clients only)
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.
Your rights in connection with your personal information
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your home address, during your working relationship with the People’s Partner Ltd so that our records can be updated. The People’s Partner Ltd cannot be held responsible for any errors in your personal information in this regard unless you have notified the People’s Partner Ltd of the relevant change.
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
- request access to your personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
- request rectification of your personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected
- request the erasure of your personal information – this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
- restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
- object to the processing of your personal information – this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
- data portability – this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.
If you wish to exercise any of these rights, please contact us. We may need to check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose you originally agreed to, unless we have another legal basis for processing.
If you believe that the People’s Partner Ltd has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at any time. The ICO is the UK supervisory authority for data protection issues.
Changes to this privacy notice
The People’s Partner Ltd reserves the right to update or amend this privacy notice at any time, including where the People’s Partner Ltd intends to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will issue you with a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.
If you have any questions about this privacy notice or how we handle your personal information, please contact our data protection lead, Audrey Limery at firstname.lastname@example.org.