ELEDECKS PRIVACY NOTICE
PURPOSE OF THIS DOCUMENT

Eledecks Limited is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you in accordance with the General Data Protection Regulations (GDPR).

It applies to all users of our portal, website, application or services.

We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain 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 and what your rights are under the data protection legislation.

WHO WE ARE

Eledecks Limited is a company incorporated in England with company registration number 05320438. Our registered office is at 14 Phoenix Park, Telford Way, Coalville, Leicestershire, LE67 3HB.

Eledecks Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

Eledecks Limited is also a “data processor”. This means that we are responsible for processing personal information about you on behalf of a data controller.

We are required under data protection legislation to notify you of the information contained in this privacy notice.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU

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 certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

Organisations using our website, portal, applications or services

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name (including business name), title, addresses, telephone numbers, and email addresses.
  • Additional information about your business and your preferences.

Employees of organisations using our website, portal, applications or services

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Gender.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave, pension and benefits information.
  • Start date and, if different, the date of your continuous employment.
  • Leaving date and your reason for leaving.
  • Location of employment or workplace.
  • Copy of driving licence if you are required to drive as part of your employment.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • Photographs.
  • Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

We may also collect, store and use the following more sensitive types of personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Trade union membership.
  • Information about your health, including any medical condition, health and sickness records, including:
    • where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
    • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
    • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
  • Genetic information and biometric data.
  • Information about criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?

Organisations using our website, portal, applications or services

We collect personal information about you when:

  • You register to use our website, portal, applications or services.
  • You place an order using our website, portal, applications or services.
  • Complete online forms, take part in surveys or participate in any other interactive areas that appear on our website or within our applications or service.
  • Interact with us using social media.
  • Contact us offline, for example by telephone, fax, email or post.

We may also collect your information when you only partially complete and/ or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We may also collect information from your devices and applications you use to access and use any of our website, applications and services and we will ask for your permission before we do so. We may do this using cookies or similar technologies or by asking you to give us access to your microphone.

We may collect information from third parties that are entitled to share that information, for example, information from credit agencies, search information providers or public sources, as permitted by applicable laws.

Employees of organisations using our website, portal, applications or services

We collect personal information about you when:

  • You or a manager or other authorised person acting on behalf of your organisation as a data controller inputs or uploads such information on to our portal or otherwise provides us with such information.

We ask data controllers to confirm that there is a lawful basis for us to process personal information about you before they share such information with us.

For information about your organisation’s management of your personal data see your organisation’s own Privacy Notice.

We may sometimes, but less commonly, collect additional information from third parties.

HOW WE WILL USE INFORMATION ABOUT YOU

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:

  1. Where we need to perform the contract we have entered into with your organisation.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest.

Situations in which we will use your personal information

We may need all the categories of information in the list above primarily to allow us to perform our contract with your organisation and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests.

The situations in which we will process your personal information are listed below.

Our portal, website, applications and services may contain technology that enables us to:

  • Check specific information from your device or systems directly relevant to your use of our portal, website, applications or services against our records to make sure that the portal, website, applications or services are being used in accordance with our end-user agreements with your organisation and to troubleshoot any problems.
  • Obtain information relating to any technical errors or other issues with our portal, website, applications and services.
  • Collect information about how you and users use our portal, website, applications and services.
  • Gather statistical information about the operating system and environment from which you access our portal, applications and services.

You can manage your privacy settings within your browser.

We may monitor and record our communications with you for training purposes, quality assurance, to record details about our portal, website, applications and services, and in order to meet our legal obligations generally.

Organisations using our website, portal, applications or services

To the extent permissible by law, we may use your information to:

  • Provide any information and services that your organisation has requested or any applications or services that it has ordered.
  • Compare information for accuracy and verify it with third parties.
  • Provide, maintain, protect and improve our portal and any applications, products and services and information your organisation has requested from us.
  • Manage and administer your use of our portal, applications products or services your organisation has asked us to provide.
  • Manage our relationship with you.
  • Monitor, measure, improve and protect our content, portal, website, applications and services.
  • Undertake testing of our portal, website, applications, systems and services.
  • Provide you with any information that we are required to send you to comply with our legal obligations.
  • Detect, prevent, investigate crime, illegal or prohibited activities or to otherwise protect our legal rights.
  • Contact you for marketing purposes or for your feedback on our portal, website, applications or services.
  • Contact you for training purposes.

Employees of organisations using our website, portal, applications or services

To extent permissible by law, we may use your information to:

  • Enable you and your employer manage everyday employment activities, for example such as but not limited to, issuing contracts of employments to you, handling leave requests, managing absences, arranging staff rotas, paying you and enrolling you in a workplace pension scheme.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, your usage of the portal will be restricted.

Change of purpose

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.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit written consent.
  2. Where we need to carry out our legal obligations or exercise rights in connection with employment.
  3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our pension scheme.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Obtaining consent

When employees input or upload personal information on to our portal they will be asked to confirm that they consent to such information being stored on our portal.

When a manager or other authorised persons acting on behalf of your organisation inputs or uploads personal information on to our portal they will be asked to confirm that they have consent or are otherwise authorised to store such information on our portal. Managers or other authorised persons acting on behalf of your organisation providing personal information about someone else, are responsible for ensuring that they comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, they must ensure that they have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that they explain to the individual how we collect, use, disclose and retain their personal information or direct them to read this Privacy Notice.

In limited circumstances, you may be approached for your written consent to allow us to process certain particularly sensitive data. You should be aware that you are not required to agree to any request for consent. However, failure to consent may lead to us being only able to provide a reduced service or you may be prevented from accessing the portal, applications, website or services.

INFORMATION ABOUT CRIMINAL CONVICTIONS

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We envisage that we will only hold information about criminal convictions if it is appropriate given the nature of the role.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and any other group companies.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU, although it is not something that we envisage that we will do. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with your organisation or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and any other group companies with whom we may share your personal information. The following activities are carried out by the third-party service providers listed here. This list may be updated from time to time:

How secure is my information with third-party service providers and other entities?

All our third-party service providers 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.

Transferring information outside the EU

We do not envisage that any information will be transferred outside of the EU, however we will notify you in writing if this position changes and provide you with further details including the name of any such country and what protection we have put in place to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

Other sites and social media

If you follow a link from our portal, website, applications or service to another site or service, which is not specifically addressed in this Privacy Notice this Privacy Notice will no longer apply as we are not responsible for the information handling practices of such third-party sites or services.

Cookies, analytical and traffic data

Cookies are small text files which are transferred from our website, portal, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our portal, website, applications and services better for you.
You may be able to configure your browser to restrict cookies or block all cookies if you wish, however if you disable cookies you may find that this affects your ability to use certain parts of our portal, website, applications or services.
We may keep a record of traffic data which is logged automatically by our servers, such as your IP address, device information, the website that you visited before ours and the website you visit after leaving our site. We also collect some site, application and service statistics such as access rates and page views. We are not able to identify any individual from such data or statistics.

DATA SECURITY

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 applied 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 endeavour to 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.

DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, and 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.

Where we act as a data controller and where necessary and to the extent permitted by law, we may retain information about you after the closure of your organisation’s account or if your organisation’s application for an account is declined or it decides not to proceed.

Where we act as a data processor 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 organisation you work for we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

It is important that the personal information we hold is accurate and current. Please keep us informed if your personal information changes.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you are acting as a client and want to review, verify, correct or request erasure of your 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 us by email at GDPR@eledecks.com. [For example a Finance manager may act on behalf of his/her employer to request correction to company data shared during the course of the contractual relationship between Eledecks and their organisation, such as company banking details.]

If you are acting as a Data Controller and want to review, verify, correct or request erasure of personal information, object to the processing of personal data, or request a transfer of a copy of personal information to another party, please use the Portal tools for this purpose where appropriate, alternatively if that is not possible please contact us by email at GDPR@eledecks.com. [For example an HR manager whose organisation subscribes to the Portal may use the export feature to provide an employee with a portable copy of personal data from Personnel Records.]

If you are acting as an employee of a client organisation (The Data Controller) and you have been issued with a self-service Personnel Dashboard you will be able to make any or all of the above requests to the Data Controller online through your dashboard. Alternatively, you can make the request offline to your employer. In the rare circumstances where Eledecks is acting as the Data Controller you can write to us at GDPR@eledecks.com.

No fee usually required

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.

What we may need from you

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.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have been asked for your consent, and have provided such consent for the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please use the online tools provided or email us at GDPR@eledecks.com. Once we have received notification that you have withdrawn your consent, we will take immediate steps to deal with your request. We will keep you informed throughout the process.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) 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 us. You 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.

CHANGES TO THIS PRIVACY NOTICE

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.