Midland Stone Centre Ltd observes the highest standards when protecting personal information and requires clear policies and practices to ensure it maintains and improves these standards on a continuous basis. This will inspire confidence in those whose personal information we store and process that it is protected and gives them control over its use. Midland Stone Centre Ltd is committed to “Privacy by Design” in its approach to projects and promoting privacy and data protection compliance. The Company recognises its responsibility to be accountable for the lawful processing of personal information.
This policy explains when and why we collect personal information about people in all circumstances, how we use it, the conditions under which we may disclose it to others and how we keep it secure. It also includes a summary of the key articles of the General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679) which apply.
This policy applies to all staff, sub-contractors and agencies working for or on behalf of Midland Stone Centre Ltd, and to the Company as a whole, whether operating as a Data Controller of customer, staff, sub-contractor and employee candidate information or a Data Processor of information on behalf of the Company’s customers.
Midland Stone Centre Ltd adheres to the following Data Protection principles as defined under the GDPR:
- Personal data shall be processed fairly and lawfully and, in particular shall not be processed unless –
(a) at least one of the conditions in Article 6 is met, and
(b) in the case of sensitive personal data, at least one of the conditions in Article 9 is also met.
- Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
- Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
- Personal data shall be accurate and, where necessary, kept up to date.
- Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Personal data shall be processed in accordance with the rights of data subjects under the GDPR.
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
- Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Midland Stone Centre Ltd has established that consent is the most appropriate lawful basis for processing personal data.
Information we collect and process as Data Controllers
Standard Personal Data
With each individual’s explicit consent, Midland Stone Centre Ltd collects and holds the following personal data on its systems, where available, in its capacity as a Data Controller:
- Prefix, First and Last Name, Suffix
- Business Title
- Date of Birth
- National Insurance Number
- Telephone Numbers, including mobile number where available
- Email Address, including private email address where specifically authorised to do so by the individual
- Business Address
- Private Address where specifically authorised to do so by the individual
- Correspondence records
- Their Consent Opt-in/Opt-out preference
- Link to their LinkedIn Profile where available
- Participation and interest in the Company’s products, services, events, research and other related information
Customer and Prospect Information
No further personal data is collected and retained on individual customers and prospects beyond the Standard Data above. This data is collected for the purposes of communicating about and delivering the Company’s products and services. It is retained for as long as the individual consents.
The following information is collected and retained on individual members of staff, in addition to the Standard Data above:
- Identification documents, including copies of at least two of Birth Certificate, Passport and Driving Licence
- Information required by HMRC (male/female, date of birth, private address, National Insurance number, employment start date, job status and student loan details)
- Information on Midland Stone Centre Ltd’s Personnel Form
- Salary, Hourly Pay, Pension and other Benefit payments
- Employment contract
- Medical information where relevant
- Curriculum Vitae and former employer references, collected at the time of recruitment
This data is collected for the purposes of:
- Meeting the Company’s obligations towards Government Agencies, including HMRC and the Pensions Authority
- Managing the Company’s Human Resources including administering the Company’s Payroll
- Ensuring employees meet or exceed the Company’s Information Security, Data Privacy and Quality standards
The data is retained for a minimum of six (6) years in order to meet statutory requirements and protect the Company from any claims made against it in future.
Candidate Employee Information
In addition to the Standard Data above, during discussions with candidates for employment with the Company, the following information is collected:
- Curriculum Vitae and former employer references
- Salary details
This data is collected for the purposes of recruiting new employees and ensuring they meet the Company’s business requirements as well as its Information Security, Data Privacy and Quality standards.
On acceptance of the Company’s employment Offer Letter, further data will be collected as noted above under “Staff Information”.
Data on unsuccessful candidates who have the potential to be recruited at a future date may be retained indefinitely with their explicit consent.
Individual Sub-Contractor Information
From an individual Sub-Contractor perspective, both of the Company’s roles as Data Controller and Data Processor apply.
A. Data Controller
As a Data Controller, the Company holds the following personal data in addition to the Standard Data above:
- Identification documents, including copies of any of the following;
- Birth Certificate, Passport and Driving Licence
- Curriculum Vitae
- Information on Midland Stone Centre Ltd’s Employee Form
- Employment Contract
This data is collected for the purposes of employing contractors and ensuring they meet the Company’s business requirements as well as its Information Security, Data Privacy and Quality standards.
B. Data Processor
Depending on the role, the sub-Contractor may be required to process personal data on behalf of the Company in its capacity as a Data Processor both for internal personnel data and for one or more of its customers.
Information we collect and process as Data Processors
From time to time and as part of the Company’s products and services, Midland Stone Centre Ltd collects and processes personal data on behalf of its customers, acting as a Data Processor. This includes names, email addresses, business addresses and in some cases salary and other confidential information.
Midland Stone Centre Ltd will comply with Article 28 of the GDPR (see Appendix 3) when acting as a Data Processor.
Midland Stone Centre Ltd can be held liable for any GDPR infringements and therefore must have the appropriate contracts in place with its Data Controller customers to mitigate this risk as well as maintaining its own internal standards.
A. Midland Stone Centre Ltd as Data Controller
Where Midland Stone Centre Ltd is the Data Controller, with Personnel and Candidate Information, the following people will be the Recipients:
- The Managing Director
- Line Managers
B. Midland Stone Centre Ltd as Data Processor
Where Midland Stone Centre Ltd is the Data Processor, the following people will be the Recipients:
- The Customer Account
- HMRC and other Government Bodies.
- The Privacy Officer, Scheduling Employees working on Customer Jobs.
C. Third Party Recipients
At no time will Midland Stone Centre Ltd release personal information to third parties without the explicit consent of the Data Subject or unless required to do so by law.
Midland Stone Centre Ltd has a duty to manage the consents granted by individuals to process their personal data and has the systems in place for this purpose. This includes continuing to offer people the option to withdraw consent at any time, with a clear process, maintaining evidence of consents (eg. who, when, how and what was communicated), reviewing them periodically and refreshing them if there is any change in circumstances.
Midland Stone Centre Ltd’s adherence to its policies and procedures with regard to Information Security and the protection of personal data. The Company uses encryption and passcodes where it is appropriate to do so, and we ensure that any Data Processor we use also implements appropriate technical and organizational measures that meet our Information Security standards.
Policy Compliance Measurement
The Company’s Information Security Impact Assessments include risk assessments for the processing of personal data. The Company will maintain records of all processing activities, whether as Data Controller or Data Processor, including details of data retention periods, transfers of personal data and any recipients outside the European Union. Although the Company is exempt from appointing a Data Protection Officer under Article 37 of the GDPR, the Company already has a Management Representative for its Information Security policies and processes, and the duties of Privacy Officer have been added to this role.
Separate contracts must be in place with any Sub-Processors the Company appoints from time to time setting out their obligations with regard to any Data Controller agreements.
No exceptions will be permitted to this policy.
An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.