What is the purpose of this document?
|HGG London Limited (hereafter referred as “HGG”, “we” or “our”) 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 during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
It applies to all contractors, sub-contractors and other third parties.
HGG 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 applies to current and former employees, workers and contractors. 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.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we 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).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We collect, store, and use the following (but not limited to) categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- Your navigation on our website (please see our Cookies Policy).
- Bank information.
There are “special categories” of more sensitive personal data which require a higher level of protection and we do envisage that we will hold or process special categories of sensitive personal data. If we are required to process special categories of sensitive personal data then we will contact you and obtain your explicit consent for us to process your special categories of sensitive personal data.
How is your personal information collected?
We collect most of this information from you directly (hardcopy or email format), form any forms you complete and submit to us, professionals we engage, automated monitoring of our websites and other technical systems, communications systems, remote access systems, email and instant messaging systems, intranet and internet facilities, telephones, voicemail, mobile phone records, relevant websites and applications.
Why we collect the information and how we use it
We will typically collect and use your personal information and sensitive personal information above for the following purposes):
- for the performance of a contract with you, or to take steps to enter into a contract;
- for compliance with a legal obligation (eg health safety legislation); and
- for the purposes of our legitimate interests but only if these are not overridden by your interests, rights or freedoms.
The situations in which we will process your personal information are listed below.
- Determining the terms on which you work for us or we work for you.
- Administering the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- Updating and enhancing customer records.
- Assessing qualifications for a particular job, project or task.
- Making arrangements for the termination of our working relationship.
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
- Ascertaining fitness to 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.
- Statistical analysis to help us manage our business eg in relation to our financial performance, client base, work type or other efficiency measures.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail 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 or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless 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 we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest.
- Where it is needed to assess working capacity on health grounds, subject to appropriate confidentiality safeguards.
Do we need your consent?
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.
We may have to share your data with third parties, including but not limited to third-party service providers such as GoDaddy, CPanel, other entities in the group, our legal advisers, and other professional advisers.
We 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 UK. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might we share your personal information with third parties?
We will 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.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are 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.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group 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.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We may use your personal data to send you updates (by email, telephone, post or social media) about our products or services that might be of interest to you including exclusive offers, promotions or products.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How we will use information about you’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations outside of HGG for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by following the opt-out links on marketing material or by contacting us by post or email by contacting us at firstname.lastname@example.org(see ‘How to contact us’).
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
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. They will only
process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
DATA RETENTION POLICY
How long will you use my information for?
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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer contractor or engaged by HGG we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
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.
By law we have to keep basic information about you (including contact, identity and financial details) for legal, regulatory and tax purposes. Please see below table confirming our retention periods:
|Record type||Retention period|
|Accident books, reports and records||6 years from the date of the last entry (if an accident relates to a child or young adult—until that person reaches 21 years)|
|Application forms and interview notes for unsuccessful candidates||3 months from the date such candidate is unsuccessful.|
|Other HR records||2 years|
|Your personal information such as your name, age, date of birth, bank information, address, telephone numbers, and personal email addresses.
|Record type||Retention period|
|Financial/Accounts records||6 years|
|Application forms, CVs and interview notes for unsuccessful candidates||3 months from the date such candidate is unsuccessful|
|Marketing||3 years unless you ‘opt out’ of the marketing material or exercise your right to withdraw in accordance with this policy.|
|Complaints records||1 year from the conclusion of the complaint|
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.
Rights of access, correction, erasure, and restriction
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, by law 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 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 contact email@example.com.
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 limitedcircumstances 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 contact firstname.lastname@example.org. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.