For most purposes under the Data Protection Act 2018 and the EU General Data Protection Regulation (together the data protection legislation) Harmony HR Solutions Ltd will be the data controller of your personal information. There may however be occasions when Harmony HR Solutions Ltd is a data processor of personal information (eg. when we are carrying out HR administration services rather than advisory services).
If you have any queries about this policy or your privacy rights, please contact Caroline Banwell at firstname.lastname@example.org or on 07964 903664.
The personal information we collect
We may collect and process the following personal information:
- identity data including your title, name, date of birth, gender, passport number and photographic identification such as your passport or driving licence
- contact data including your email and postal address and telephone number
- services data including details about payments from you and other details of the service you have purchased from us
- financial data including your bank account details
- technical data including information collected when you access our website including your IP address
- professional data including your job title and information relating to your employment
- HR services data including personal information provided about employees or others you engage for the purpose of obtaining advice
- sensitive data (now known as special categories of personal data) including information about your health and the health of some of your staff where you have provided this information to us in order for us to carry out our services and your political opinions or religious or philosophical beliefs.
This data is normally gathered by direct interaction, by phone, letter or in email correspondence save for technical data which is collected electronically. We may also gather your personal data from business events and where you provide your details to us via our website to request our HR and legal updates.
We also use publicly available sources of information such as public registers of companies and charities such as information held by Companies House and with the Charities Commission.
If you fail to provide us with the personal data we request we may not be able to provide you with our services.
How we use personal information and the legal bases we rely on
We will only use personal data when the law allows us to.
We will use your contact data, financial data, services data, professional data, HR services data and sensitive data to enable us to provide you with our services. This use of this personal information is necessary to perform our contract with you.
We may also use your contact data to provide you with updates on HR and legal developments. We believe that it is in our legitimate interests to provide such information so as to be able to help update our clients and prospective clients on HR and legal developments and to assist us to market our services effectively.
We may disclose HR services data in defending any claims against us on the basis that this is in our legitimate interests.
We may use Google Analytics to monitor how our website is being used in which case Google may use your IP address information to assess how you have used our website. This will enable us to improve our website which is in our legitimate interests.
Transfer of personal data
We will not disclose your information to any person without your prior consent unless we are required to disclose it by law.
We will not actively send your data outside the EU but we use cloud storage and we may use Google Analytics and Google or Microsoft may do this. Google and Microsoft subscribe to the EU-US Privacy Shield framework which means that they have agreed to work with the appropriate regulatory authorities to resolve any complaints regarding the transfer of personal data where these complaints cannot be resolved directly. Organisations subscribing to the EU-US Privacy Shield framework (eg. Google, Dropbox, Mailchimp) are considered to be permitted destinations for personal data by the EU.
How long we keep personal data
We will not retain your data for longer than necessary. We will retain personal data relating to the services we have provided to clients for seven years after conclusion of the matter to which the data relates on the basis that it is in our legitimate interests to be able to defend any claims relating to the services we have provided.
Questions and concerns
If you have any questions or concerns about our use of your personal information, please let us know by sending an email to email@example.com. You may raise any concerns or obtain more information from the Information Commissioner’s Office (ICO) (https://ico.org.uk/concerns/).
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
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.
Right to 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.
Right to 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 or you have successfully exercised your right to object to processing (see below). 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.