What is the purpose of this document?
Carmen’s is a “data controller”. This means that we are responsible for deciding how we hold and use personal information. This privacy notice explains what we do with your personal data when you are applying to use our services (whether as a client, Tenant, employee, worker or contractor) and when you are as you leave us we hope to continue our relationship with you. It also explains what we do when we work with clients. This will include any data a client may provide to us when enquiring about our services or when a client shares this information to us by email, telephone, mail, in person or otherwise, including contact details for the purpose of providing our services to a client. The privacy notice also applies to when we are receiving a service; using your data to ask for assistance in relation to one of our clients or when you are visiting our website. It makes you aware of how and why your personal data will be used, namely for the purposes of the security, referencing and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
We are committed to protecting the privacy of our clients and users of our website and ensuring a secure user experience by complying with data protection law and principles. This privacy notice applies to the personal data of our website users, candidates, clients, suppliers and other people whom we may contact in order to find out more about our candidates. This privacy notice aims to give you information on how Carmen’s collects and processes your personal data.
You have a legal right to object at any time to the use of your personal information for direct marketing purposes and the processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
· Used lawfully, fairly and in a transparent way.
· Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
· Relevant to the purposes we have told you about and limited only to those purposes.
· Accurate and kept up to date.
· Kept only as long as necessary for the purposes we have told you about.
· Kept securely.
The kind of information we hold about you
In connection with your application to use our service, we will collect, store, and use the following categories of personal information about you:
· The information you have provided to us in your email and covering letter.
· The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications, bank statements.
· Any information you provide to us during an consultation or the application process.
We may also collect, store and use the following types of more sensitive personal information:
· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
· Information about your health, including any medical condition, health and sickness records.
· Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates and clients from a number of different sources, including the following:
· You, when you wish to become a candidate or client.
· When you create an account on our website.
· When you subscribe to updates including marketing and job alerts.
· Disclosure and Barring Service in respect of criminal convictions.
· A candidate’s named referees.
· Qualification reference checking.
· Verification of details that you have provided from third party sources.
· Fit tests.
· Professional social media and networking sites (including LinkedIn).
· Boards that you have registered your details on.
· Online libraries.
How we will use information about you
We will only use your personal data when the law allows us to. Most commonly, we will use the personal information we collect about you for our legitimate business purposes including to:
· Carry out background and reference checks, where applicable.
· Communicate with you about the our process, including asking you to leave a review or take a survey.
· Keep records related to our processes.
· To maintain our business relationship, where you are a user of our website, a client or candidate.
· To provide our professional services to you and answer your enquiries.
· To enable you to submit your general applications, to apply for specific treatments or to subscribe to our offers alerts.
· To retain your details and notify you about future offers and opportunities other than for the specific subject which you have contacted us about.
· To register you with us and/or register an account for you on our website.
· To fulfil our contractual obligations with our clients, including providing coaching services and assisting with a particular requirements.
· To deliver relevant marketing services, advise you of industry news and updates, competitions, events, reports and other information.
· To carry out banking or invoicing duties.
· To obtain equal opportunities and diversity information.
· To administer and protect our business (including but not limited to troubleshooting, testing, support, hosting of data).
We also need to process your personal information to decide whether to enter into a contract with you.
Having received your request for services and consultation form, we will then process that information to decide whether you meet the requirements to be worked with. If you do, we will offer you suitable appointment times.
The legal basis for processing your personal information
· If it is necessary for entering into or performing a contract and it is in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us;
· If it is necessary for compliance with a legal or regulatory obligation;
· If it is necessary for the purposes of legitimate interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and more secure experience;
· In some circumstances we may ask for your consent to process your personal data in a particular way.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of medical history), we will not be able to work with you.
For example, if we require a credit check or references and you fail to provide us with relevant details, we will not be able to work with you.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
· We will use information about your disability status to consider whether we need to provide appropriate adjustments during the treatment process, for example whether adjustments need to be made during treatment or test.
· We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We envisage that we will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to work with you (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information for the purposes of processing your application or in case of personal safety being at risk. 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.
We will only share your personal information with trusted third parties, where we have retained them to provide services that you or our clients have requested, such as those listed in the section above “how is your personal information collected”. We may also share your personal information with third parties who perform duties on our behalf such as professional advisors; specialist IT support, supplier and sub-contractors; providers of event management and ticketing services such as eventbrite; outsourced service providers of accounting and banking services and HR and marketing services and any regulatory or legal body that we are obliged to report to.
We have put in place 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 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.
Should our website include links to third party websites, clicking on those links may allow third parties to collect or share data about you. We do not control such third party websites and have no responsibility for their privacy statements. We encourage all website users to read the privacy notice of every website he or she visits.
How long will you use my information for?
We will usually retain your personal information for a period of five to 7 years. As we support clients over many years, the purpose for which we retain candidate data is often an ongoing purpose. We also retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
We conduct regular data cleansing audits with our clients to ensure that we do not hold data for longer than is necessary. To determine the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of personal data and the purposes for which we process such personal data. We also take into account, whether we can achieve those purposes through other means and the applicable legal requirements.
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Anybody who wishes to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, he or she should not hesitate to contact Carmen Maynes.
Rights of access, correction, erasure, and restriction
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. You will not be charged a fee to access such personal data. However, we may charge a reasonable fee if your request was clearly unfounded, repetitive or excessive.
· 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 want to review, verify, correct or request erasure of your personal 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 Carmen Maynes in writing.
Right to withdraw consent
When you applied to us, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Carmen Maynes. Once we have received notification that you have withdrawn your consent, we will no longer process your application and we will dispose of your personal data securely.
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 the DPO (contact details below).
Full name of legal entity: Carmen’s Beauty & Holistic Therapy
DPO: Carmen Elizabeth Maynes – Director
Direct: 07392 378826
Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact Carmen Elizabeth Maynes as set out above. If you’re not happy with the outcome 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.