The Companies are 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 employees, workers and contractors.
The Companies are 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.
The Companies include Stonbury Limited, Kingcombe Stonbury Limited, Stonbury Scotland Limited and ITS Stonbury Limited.
Stonbury Limited provide GDPR provision to the businesses noted. The Companies contact details are: Stonbury Limited (company number 01721842). Registered Office: Chawston House, Chawston Lane, Chawston, Bedfordshire, MK44 3BH. Telephone: 01234 750924.
We will comply with data protection law. This says that the personal information we hold about you must be:
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 will collect, store, and use the following categories of personal information about you:
We may also collect, store and use the following "special categories" of more sensitive personal information:
We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
“Special categories” of particularly sensitive personal information require higher levels of protection. This information includes the following information: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, health, sex life or sexual orientation.
In so far as your personal information amounts to special categories of personal data, in addition to the above, we will most likely use your personal information in the following additional circumstances:
In this section we use asterisks (e.g. [*] or [**] or [***]) to indicate which legal basis we rely on when processing different types of information (as we indicate below).
We need all the categories of information in the list above primarily to allow us to perform our contract with you [*] and to enable us to comply with legal obligations [**]. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties [***], provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
We will use your particularly sensitive personal information in the following ways:
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
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.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. 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.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may want to transfer your personal information outside the EU in limited circumstances but will let you know if we do and the safeguards we will put in place.
If we do, you can expect a similar degree of protection in respect of your personal information.
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.
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes: Royal London – pension provider; Canada Life – life assurance; Caboodle Technology, PerksatWork – benefits platform provider; BUPA, Simply Health, Vitality, Probitas – healthcare; Veriphy – background checks; Drivercheck – driving licence checks; Vacancy Filler – applicant tracking system.
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.
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.
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 will not transfer your personal information outside the EU.
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.
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. 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. We also take into account the limitation periods applicable for making any claims against us which features in our decision-making on retention.
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 an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our policies.
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.
Under certain circumstances, by law you have the right to:
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 Loraine Thomas, Group Head of HR in writing.
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.
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.
In the limited circumstances where we have relied on your consent for the collection, processing and transfer of your personal information for a specific purpose (which will be rare), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Loraine Thomas Group Head of HR at the address indicated below. 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.
We have appointed Chris Challands, Operations Director to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Loraine Thomas Group Head of HR, Chawston House, Chawston Lane, Chawston Beds MK44 3BH. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
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.
If you have any questions about this privacy notice, please contact Loraine Thomas Group Head of HR Chawston House, Chawston Lane, Chawston, Beds MK44 3BH.