This privacy Notice applies to all activities for processing of personal information by Positive Solutions HR Limited, a company registered in the Isle of Man, referred to in this privacy notice as “we” or “us” or “The Company”.
The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal Information” is details about a living individual who can be identified from that information (either by itself or when combined with other information).
We may update this Privacy Notice from time to time and will publish a revised version. You can request a copy of our up to date Privacy Notice from time to time by contacting our Data Protection Officer.
Maintaining the security of your data is a priority for us and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. We also want to be transparent about what data we collect about you and how we use it.
The policy covers:-
- What personal data we collect;
- How we obtain your information;
- How long we keep your data;
- How we use your data;
- How we protect the data we hold;
- Your legal rights relating to your personal data.
1. WHAT DATA DO WE COLLECT?
We collect data which is given to us by visitors to our website or through our normal day to day interaction with clients, colleagues and partners. This may include:
- Name, e-mail address, phone number, information about you or your business and other information which is relevant to your enquiry.
- CV’s or application in respect of a job vacancy or speculative job new enquiry.
- Information you have provided via the comments form on our website.
- Where we are working for you directly or on behalf of your employer we may hold detailed personal information about you including age, date of birth, marital status and gender; full contact details: postal address, telephone numbers (including mobile numbers) and e-mail address; Details of your Right to Work and Work permit information; National insurance or tax reference numbers or codes: CV and any proof of ID documentation; Company registration details and tax information for payroll; Information in respect of criminal records or credit checks; Details of Referees and references provided; Qualification details and copy certificates; Salary and benefit information.
- Technical information about your device such as address, operating system, browser, timezone settings, the internet address of the website from which you linked directly to our website, URL clickstream data, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.
Our services are not intended for children and we do not knowingly collect data relating to children.
We may also hold certain special categories of information for specific purposes, such as detecting and preventing financial crime or to comply with our Regulatory requirements. We will only process special categories of information where we have your explicit consent or we are otherwise lawfully permitted to do so. This information may include:-
- Information about racial or ethnic origin
- Religious or philosophical beliefs
- Details of health or medical conditions.
Where permitted by law we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption and international sanctions.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Clients have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
2. HOW WE OBTAIN YOUR INFORMATION
The information we hold is made up of personal information which is collected directly from you and by your employer on your behalf. The information is If you are a client we may also hold information about your business, the proprietors, officers and beneficial owners of that business and it’s transactions. This includes:-
- Information which is freely given to us by you either by electronic, verbal or other means, including via our website, e-mail or social media.
- Data provided on the comments form on our website.
- Information we receive from third parties, e.g., employers, credit reference, fraud prevention or government agencies;
- Information which is gathered from public sources, such as the press, published documents, company registers, electoral register etc.
- Via Cookies when you visit our website.
3. HOW WE USE YOUR DATA
We may process your information to provide our services to you and fulful our contractual obligations. Please note if you do not agree to provide us with the information we request it may not be possible for us to continue to provide our services to you. This may include processing to:-
- Provide and administer those services and products throughout your relationship with us, including, setting up and delivering our services, collecting and issuing documentation, carrying out your instructions;
- Confirm your identity and perform checks for the purpose of preventing and detecting crime and to comply with laws relating to right to work and remain, money laundering, fraud, terrorist financing, bribery and corruption and international sanctions;
- Protect customers, employees and other individuals and maintain their safety, health and welfare;
- Comply with our legal and regulatory obligations;
- To help with spam detection through our website.
- Prevent, investigate and detect crime, fraud, including working with law enforcement agencies;
- Protect the Company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to the Company;
- Effectively handling any legal claims or regulatory enforcement actions taken against us or our clients and;
- Fulfil our duties to our customers, colleagues, shareholders and other stakeholders.
- Investigate and resolve complaints;
- Manage regulatory matters, including investigations and litigation
4. SHARING DATA WITH THIRD PARTIES
In order to make certain services available we may need to share your personal data with service partners. These include service providers, government bodies, regulators, law enforcement agencies, courts/tribunals, insurers/benefits and consultants/agents.
We may access and use information from credit reference and fraud prevention agencies prior to our dealing with you. This will allow us to make decisions about our ability to work with you, to prevent criminal activity, fraud and money laundering, to check your identity and verify the accuracy of the information you have provided to us.
We only allow our service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls and in the following instances:-
- To exercise our legal rights (for example in court cases);
- Where we are required to do so for the prevention, detection, investigation of crime or prosecution of offenders;
- For the protection of our employees and clients;
- Where the information is required to enable any agents or sub-contractors acting on our behalf to provide a service to us;
- With third party guarantors or other companies that provide you with benefits or services (such as insurance cover) associated with your product or service;
- Our suppliers and service providers to facilitate the provision of the website, related services and our client services, including IT consultants, web hosting providers, recruitment service providers, consultants and similar third parties.
- We have your permission.
Other third parties
Aside from our service providers, we will not disclose your personal data to any third party. We will never sell or rent our customer data to other organisations for marketing purposes.
5. TRANSFERRING INFORMATION OVERSEAS
We may transfer your information to organisations or individuals in other countries on the basis that the recipient protects it in the same way as we would and in accordance with any applicable law.
In the event that we transfer information outside of the EEA we will only do so where:-
- The European Commission has decided that the country or the organisation we are sharing your information with will give your information adequate protection;
- The transfer has been authorised by the relevant Data Protection authority and/or
- We have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission or the Isle of Man Data Protection Authority) when we are confident your data is protected.
6. HOW LONG DO WE KEEP YOUR DATA?
We manage our records to help us to provide a service to our Clients, for example, dealing with any queries you may have and to comply with legal and regulatory requirements.
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, the nature of the activity, product or service and any relevant specific requirements for your particular location.
Should you wish to obtain specific information about retention of your own data, please contact the Data Protection Officer.
7. COOKIE STATEMENT
We may collect different types of cookies for the following purposes:-
- Cookies which are essential to allow you to move around our website and use it’s features.
- Information in an anonymous form about how visitors use our website, including counting the number of visitors and how the website is used.
- Cookies which remember choices you make (such as your user name, language or the region you are in, if applicable) and provide more enhance personal features.
- Cookies which allow you to connect with social media networks such as Facebook, Twitter, LinkedIn and Google+. These are persistent cookies which will be kept on your device until they expire.
8. HOW WE PROTECT YOUR DATA
We are committed to keeping your personal data safe and secure. The access to your details are limited within our systems and our systems are protected by appropriate security controls, including password protection and anti- virus software which protect our systems from external attack and unauthorised access.
We recommend that you install your own security measure, firewalls, software, spyware and other appropriate security procedures and virus protection measures.
Please note that transmission of information via the internet is never completely secure and whilst we do our best to keep our own systems secure, we cannot control the entirety of the internet and cannot therefore guarantee the security of your information as is transmitted to and from our website.
9. YOUR RIGHTS
You have the following rights:
- the right to ask what personal data that we hold about you at any time;
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge;
- the right to ask us to delete details we hold about you, unless we are legally bound to keep the data;
- To ask us to restrict the processing of your personal information;
- You have the right to receive any data we hold about you in portable format;
- To object to the processing of your personal information.
- Where you have given specific consent to process personal data, you have the right to withdraw consent at any time;
- You have the right to lodge a complaint with the Isle of Man Information Commissioner’s Office. Further information, including contact details are available on inforights.im
If you have any questions about how we use your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by e-mail email@example.com.