In accordance with the General Data Protection Regulation (GDPR), Peninsula Business Services have implemented this privacy information notice to inform you, our current and former clients, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
This notice applies to current and former clients.
We are a Data Controller of the personal data that you supply to us under your contract with us.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing is fair, lawful and transparent
- data is collected for specific, explicit, and legitimate purposes
- data collected is adequate, relevant and limited to what is necessary for the purposes of processing
- data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We keep several categories of personal data on and from our clients in order to carry out effective and efficient processes. We hold the data within our computer systems, for example, the systems that we use to provide our advice service and case management systems.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers, job title, email addresses etc for the main contact and other contacts for the delivery of the service
- IT service use including online service access records.
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly when the contract is signed, during the onboarding process and during the contract and after the contract has ended.
Personal data is kept in files or within the Company’s IT systems.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the service contract we have with you, including ensuring we can deliver the service to you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Set up your account||Performance of the contract|
|Carry out the delivery of the services you have on your account Performance of the contract||Ensuring payments are made under your account Performance of the contract|
|Ensuring VAT and insurance premium tax is paid||Legal obligation|
|Carrying out checks in relation to your company status and validating the information supplied to us||Legal obligation|
|Making financial decisions in relation to entering both initial and subsequent contracts||Our legitimate interests|
|Making decisions about service delivery methods||Our legitimate interests|
|Ensuring efficient administration of contractual services to you||Our legitimate interests|
|Effectively monitoring the service provided including adherence to commitments and service entitlements||Our legitimate interests|
|Maintaining up to date records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in place||Our legitimate interests|
|Dealing with legal claims made against us||Our legitimate interests|
|Preventing fraud||Our legitimate interests|
|Ensuring our administrative and IT systems are secure and robust against unauthorised access||Our legitimate interests|
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership
- genetic and biometric data.
We do not carry out processing activities using special category data.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you. This could include being unable to offer you services or administer existing contractual services.
G) CRIMINAL CONVICTION DATA
We do not carry out processing activities using criminal records data.
H) WHO WE SHARE YOUR DATA WITH
All employees within Peninsula that handle your personal data are trained in ensuring data is processed in line with GDPR.
Data may be shared with other companies within the Peninsula Group of Companies for the following reasons: to advise you other services the Peninsula Group could offer you, for administration of services specifically supplied by companies within the Peninsula Group. For example, Peninsula/Croner provides employment and health and safety services, and Bright HR Ltd provides the online services HR Online and Bright HR. Your data may be shared with Bright HR Ltd and other companies within the Peninsula Group to facilitate the delivery of all the services you are contracted to receive or to notify you of other services our group can offer you. All electronic marketing will be conducted in compliance with the Privacy & Electronic Communications Regulations.
Your data is not shared with other third parties, except for other reasons such as to comply with a legal obligation placed upon us or for service delivery. We have a data processing contract in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We may share your data with bodies outside of the European Economic Area. These countries include Canada, Australia, New Zealand, and the Philippines (and from March 2019: the United Kingdom) and the reason for sharing with these countries is to facilitate our legitimate business interests in providing you with the contracted services where the Croner-i employee or supplier responsible for the provision of the service is based outside the EEA. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws:
The data processing systems in use at other companies have comparable levels of security and safety to the systems in operation in countries within the European Economic Area.
I) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the duration of your service contract plus 7 years from the date that service contract with us terminates, although in some cases we will keep your data for a longer period after your contract has ended. Some data retention periods are set by the law.
K) AUTOMATED DECISION MAKING
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
L) CLIENT RIGHTS
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you. More information on this can be found in the section headed "Access to Data" below and in our separate policy on Subject Access Requests;
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as 'rectification';
- the right to have data deleted in certain circumstances. This is also known as 'erasure';
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party. This is also known as 'portability';
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
N) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
O) DATA PROTECTION COMPLIANCE
The Group Data Protection and Compliance Officer is:
Telephone 0844 892 2779