This document explains how we use your personal data.
We are committed to ensuring the privacy of our employees and potential candidates for job vacancies. In this policy we explain how we hold, process and retain your personal data.
- How we use your personal data
- This section provides you with information about:
- what personal data we hold and process;
- in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
- the purposes for which we may process your personal data; and
- the legal grounds on which we process your data.
- Personnel data
We may process information that you provide to us, or that we may collect from third-party sources such as websites on which our vacancies may be advertised, or through recruitment agencies (“personnel data“). This personnel data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, employment history, immigration status, salary, curriculum vitae, job preferences and employment details.
We may also process your personnel data in relation to job vacancies that you have applied for, generally processing any job applications, facilitating the recruitment process and furthering our relationship with you. The legal basis for this processing is our legitimate interest in finding an appropriate person for a particular role.
Where you have provided your consent for us to do so, we may consider you for opportunities that you did not specifically apply for but which we think might be a good fit for your skillset.
We may collect your details from third-party sources where we identify that you are suitable for an available vacancy with us. Where we do so, we will contact you to ask whether you would like to be considered for an appropriate vacancy. Our use of the personnel data in these circumstances is limited to making contact with you to determine whether you are interested in working for us and applying for a role. The legal basis for this processing is our legitimate interest as a business in finding an appropriate person for a particular role.
Where you have given us consent to process your information for the purposes detailed above, we will enter the personnel data into our central recruitment database.
If we employ you, we may hold your personnel data on our personnel file. We may use your personnel data during the course of your employment for various reasons such as, contacting you where necessary with details about the company or our relationship with you (for instance if you are promoted or receive a salary increase, or if anything about the employment relationship that we have with you changes in any way) or for considering which duties and responsibilities would be suitable for you. The legal basis for this processing is for the performance of our employment contract with you.
- Employment data
Throughout the course of your employment by us, we may create, collect, hold and use data about you (“employment data”). This may include payment details, medical and health information, information regarding your criminal record, and other information that may be generated during the course of your employment such as flexible working requests, general performance reviews and appraisals. We process this information for the purposes of learning and development, the promotion of effective business practices, statutory sick pay purposes, monitoring sickness absence, the administration of your employment and general business management purposes. The legal basis for this processing is for the performance of our employment contract with you.
- Website data
We may process data about your use of our website and services (“website data“). The website data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- Correspondence data
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- Payment data
We may process payment information relating to the payment of your salary, and PAYE tax, National Insurance Contributions and pension payments on your behalf (“payment data“). The payment data may include your contact details, your card and bank details and the transaction details. The payment data may be processed for the purposes of administering the payment and keeping proper records of those payments. The legal basis for this processing is the performance of a contract between you and us.
- Other processing activities
In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Sensitive Personal Data
During the course of your employment, we may ask you to provide us with sensitive personal data, including details about your physical and mental health, your race and/or religion or sexuality. We may use this data to in order for us to comply with our commitment to equal treatment within the workplace and our obligations under our employment contract to you,
The legal basis for this processing is consent.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Providing your personal data to others
- Our insurers/professional advisers
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
- For administrative services or staff benefits
We may disclose employee personal data to third parties such as those administering our payroll system or staff benefits (this will include the providers of pension schemes).
- Where we provide your personal data to any third party
Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.
- To comply with legal obligations
In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual.
- Transfers of your personal data outside of the European Economic Area
- Where your personal data is transferred outside of the EEA, we will ensure that either (a) The European Commission has made an “adequacy decision” with respect to the data protection laws of the country to which it is transferred, or (b) we have entered into a suitable data processing agreement with the third party situated in that country to ensure the adequate protection of your data. In all cases, transfers outside of the EEA will be protected by appropriate safeguards.
- You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:
- Personnel data will be retained for  years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Employment data will be retained for  years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Website data will be retained for  years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Correspondence data will be retained for  years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- Payment data will be retained for 6 years following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
- We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of changes to this policy by email.
- Your rights
- You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- your request not being found to be unfounded or excessive, in which case a charge may apply; and
- the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
- We may withhold personal information that you request to the extent permitted by law.
- You may instruct us at any time not to process your personal information for marketing purposes.
- In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- The rights you have under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- Your right to access your data
You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
- Your right to rectification
If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
- Your right to erasure
In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
- Your right to restrict processing
In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- Your right to object to processing
You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
- Your right to object to direct marketing
You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
- Your right to object for statistical purposes
You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
- Automated data processing
To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
- Complaining to a supervisory authority
If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
- Right to withdraw consent
To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- Exercising your rights
You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
- Our details
- Liaison Financial Services Limited (as the parent company) is registered in England and Wales under registration number 06426660, and our registered office is at Estate House, Evesham Street, Redditch, Worcestershire, B97 4HP.
- You can contact us:
- by post, using the postal address given above;
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to time.
- Data protection officer
Our data protection officer’s contact details are: Dominic Hutchinson-Backer, who can be contacted via email firstname.lastname@example.org or telephone 0845 603 9000.