Website Privacy Notice and Policy
Roots HR respects your privacy and is committed to protecting your personal data. This privacy notice aims to inform you about how we look after your personal data when you visit our website (regardless of where you visit it from); sign up to receive any marketing information, updates or newsletters, or purchase a product or service. It tells you about your privacy rights and how the law protects you. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This information was last updated on 25th May 2018.
Our full details are:
Roots HR CIC
First Floor Offices
35 & 36 Worcester Street
Kidderminster, DY10 1EW
Tel: 01562 840060
Data Protection Officer: Jan Golding, Chief Executive, email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
- your use of our website and any online services we provide
- when you request information from us, including HR tools and resources, marketing information, factsheets, proposals and quotations etc.
Separate Privacy Notices are available in respect of other circumstances, such as when you apply for employment with us. The relevant notice will be provided to you separately as required.
2. The data we collect about you
‘Personal data’ is any information about an individual from which that person can be identified. It does not include anonymised data where identifying characteristics have been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data which may include your name, username or similar identifier, marital status, title, date of birth and gender
- Contact Data which may include address, billing address and details, email addresses and telephone numbers
- Financial Data which may include bank account and payment card details
- Transaction Data which may include details about payments to and from you and other details of products and services you have purchased from us
- Technical Data which may include internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
- Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences and any feedback and survey responses
- Usage Data which may include information about how you use our website, products and services
- Marketing and Communications Data which may include your preferences in receiving marketing from us and your communication preferences
We also may collect, use and share what is known as ‘Aggregated Data’ (such as statistical or demographic data) for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Unless specifically required for the purpose or in the course of providing specific advice and services to you, we do not collect any Special Categories of Personal Data about you or your employees, workers, consultants or other parties associated with you. These categories of data include details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
Unless specifically required for the purpose or in the course of providing specific advice and services to you, we do not collect any information about criminal convictions and offences about you or your employees, workers, consultants or other parties associated with you.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How your personal data is collected
We may use different methods to collect data from and about you. These include:
- Direct interactions. You may provide us with personal data for example when you:
– visit our website
– apply for our products or services
– subscribe to any of our services or publications or request marketing information to be sent to you
– complete a survey or give us some feedback
– report a problem with any on-line services we provide or our website
- Third parties or publicly available sources. Examples of this might include:
– Analytics providers or search information providers/engines
– Advertising networks
– Data brokers or aggregators
– Companies House and the Charity Commission
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need it to perform a contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Generally we do not rely on consent as a legal basis for processing your personal data except in relation to sending direct marketing communications to you via email or direct messaging via a social media platform. You have the right to withdraw consent to marketing at any time by contacting us.
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register or subscribe you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver services to you, including:
(a) Manage payments, fees and charges
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests
|To manage our relationship with you which will include:
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content to you and measure or understand the effectiveness of our communications with you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data as described above to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will not share your personal data with any other company for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us or by selecting the ‘unsubscribe’ option which is include with each such communication to you.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of the purchase of a product or service or an instruction to us to act on your behalf.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Below is a list of cookies used on our website:
|webfxtab_documentPane||These cookies have no impact on your user experience and store no personal information. These cookies are automatically added by the software that runs this website, but we do not use them in any way.|
|_utma||These cookies enable Google Analytics to function. Google Analytics helps us take and analyze visitor information. For example, it tells us how many visitors our site has, how many times they visit, how long they stay on our site and which pages are most popular.|
|civicAllowCookies||Cookie Control cookies. These cookies are set in order to remember preferences in regards to cookies.|
Below are instructions on removing cookies for all major web and mobile browsers so that you can find out about how to manage your cookies.
- Internet Explorer:https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
- Google Chrome:http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
- Safari iOS:https://support.apple.com/en-gb/HT201265
- Android: Turn off cookies in the browser
- Blackberry: Turn off cookies in the browser
- Windows Phone: Changing privacy and other browser settings
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
5. Disclosures of your personal data
Any third party joint data controllers or third party data processors we engage in the normal course of our business are required by us to respect the security of your personal data and to treat it in accordance with the law. They are only permitted to process your personal data for specified purposes and in accordance with our instructions.
6. Transferring data outside the EEA
We do not currently transfer your data outside of the EEA, except in the case of our use of a marketing automation platform (currently Mailchimp) which we use to transmit emails on our behalf. As part of our commitment to protecting your data we strive at all times to ensure that full and GDPR-compliant arrangements between Roots HR CIC and our chosen automation platform provider are in place.
7. Data security
We strive to maintain appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the ICO of a breach where we are legally required to do so
8. Data retention
We will only retain your personal data 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.
We keep basic information about the clients we serve (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.
In some circumstances you can ask us to delete your data. This is explained in section 9 – Your legal rights below. To do so you should contact us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below you should contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us to confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We will endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have a right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
© Roots HR CIC. All rights reserved. 25 May 2018