Data Protection Policy
FISco (UK) Limited (The Company) is committed to being transparent about how it collects and uses personal data and to meeting its data protection obligations. This policy sets out The Company’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices, former employees and customers referred to as personal data.
DATA PROTECTION PRINCIPLES
The Company processes personal data in accordance with the following data protection principles:
- The Company processes personal data lawfully, fairly and in a transparent manner.
- The Company collects personal data only for specified, explicit and legitimate purposes.
- The Company processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- The Company keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- The Company keeps personal data only for the period necessary for processing.
- The Company adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
The Company tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. HR-related data will not be shared with third parties, except as set out in privacy notices. Where the company relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
Where the company processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.
The Company will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. Personal data gathered relating to customers/suppliers are stored in our in house facilities management software (CIMS/TASKYE), or on our file server and are stored in the lawful basis of a contract agreement. The periods for which The Company holds personal data are contained in its privacy notices to individuals.
The Company keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
To make a subject access request, the individual should send the request to firstname.lastname@example.org
The Company takes the security of personal data seriously. The Company has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. More information is included in The Company’s Data Security Policy.
Where the company engages third parties to process personal data on its behalf, such parties do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
If the company discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The Company will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
INTERNATIONAL DATA TRANSFERS
The company will not transfer personal data to countries outside the EEA without specific written permission from the data owner.
Individuals are responsible for helping the company keep their personal data up to date. Individuals should let the company know if data provided to the company changes, for example if an individual moves to a new address or changes his/her bank details.
Individuals may have access to the personal data of other individuals and of our customers and clients during their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, The Company relies on individuals to help meet its data protection obligations to staff and to customers and clients.
Individuals who have access to personal data are required:
- to access only data that they have authority to access and only for authorised purposes;
- not to disclose data except to individuals (whether inside or outside the company) who have appropriate authorisation;
- to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
- not to remove personal data, or devices containing or that can be used to access personal data, from the company’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
- not to store personal data on local drives or on personal devices that are used for work purposes; and
- to report data breaches of which they become aware to the GDPR representative immediately.
Further details about The Company’s security procedures can be found in its data security policy.