Grafters Recruit Limited is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out our commitment to data protection, and individual’s rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees, referred to as personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.
This policy does not form part of an employee’s contract of employment and may be amended at any time without prior notice.
If you consider that the policy has not been followed in respect of either your own personal data or that of others, you should raise the matter with your Manager.
“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
The Company processes personal data in accordance with the following data protection principles:
As a data subject, individuals have a number of rights in relation to their personal data. Individuals have the right to make a subject access request. If an individual makes a subject access request, the Company will tell him/her:
We will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
If the individual wants additional copies, we will charge a fee, which will be based on the administrative cost to the Company of providing the additional copies.
To make a subject access request, the individual should send their request to the Data Protection Officer. In some cases, the Company may need to ask for proof of identification before the request can be processed. We will inform the individual if we need to verify his/her identity and the documents we require.
The Company will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the Company processes large amounts of the individual’s data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, the Company is not obliged to comply with it. Alternatively, the Company can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the Company has already responded. If an individual submits a request that is unfounded or excessive, we will notify him/her that this is the case and whether or not we will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the Company to:
We take the security of personal data seriously. We have 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.
Where the Company engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, and are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Some of the processing that the Company carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, we will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
If the Company discovers that there has been a breach of 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. We 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, we 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.
Personal data may be transferred to countries outside the EEA for references purposes. Data is transferred outside the EEA on the basis of compliance with this policy.
Individuals are responsible for helping the Company keep their personal data up to date. Individuals should let us know if data provided to us changes, for example if an individual moves to a new house or changes his/her bank details.
Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the Company relies on individuals to help meet our data protection obligations to staff, customers and clients.
Individuals who have access to personal data are required:
Further details about the Company’s security procedures can be found in our Data Security policy.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under our Disciplinary Procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to summary dismissal.
We have put in place procedures and technologies to maintain the security of all our company related data, including the data of our clients or other personal data that is processed for business purposes. Data may only be transferred to a third party data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
This policy does not form part of any employee’s contract of employment and may be amended at any time.
If you consider that this policy has not been followed, you should raise the matter with your manager.
Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including summary dismissal.
Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:
Security procedures include (but are not limited to):
Grafters are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
Grafters may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1st May 2018.
What we collect
We may collect information including but not limited to the following:
We require this information to understand your needs and provide you with a better service, and in particular but not limited to the following reasons:
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Should there ever be a breach of data security, this would be reported to the Information Commissioners Office (ICO).
Your rights are outlined below but are not exhaustive.
All data is held for a minimum of 6 years in line with legislative guidance. Except in cases for the defence, establishment or exercise of legal claims.
We will not sell, distribute or lease your personal information to third parties unless we have your permission, it is in your legitimate interests or we are required by law to do so. If you believe that any information we are holding on you is incorrect or incomplete, please speak to your local branch. We will promptly correct any information found to be incorrect.
Subject access requests can be requested by emailing firstname.lastname@example.org. This can be sent to you electronically and there may be a nominal fee incurred for this. If you find it impossible or unreasonably difficult to make a request in writing, we will, under the Equality Act 2010 assist you with making any requests.
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Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.