Business Cleaning Services - BCS

 

Frequently Asked Questions:  Privacy & Data Protection

BCS’ Staff Privacy Notice

 

BACKGROUND:

 

Business Cleaning Services (“BCS” / “The Company”) understands that your privacy is important to you and that you care about how your personal data is used.  We respect and value the privacy of all of our Employees and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

1. Information About Us

BCS

Jubilee House

3 The Drive

Great Warley

Brentwood

Essex

CM13 3FR

 

Data Protection Duty Holder:  Administration Manager

Email: dpo@bcsonline.org.uk

Tel: 01268 492 800

Postal Address: as above

 

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed.  It also explains your rights under the law relating to your personal data.

 

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified.  Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

 

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data.  This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you.  Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.  Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.  Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability.  This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling.  We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

 

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

· Name;

· Date of birth;

· National Insurance number or other similar identifiers;

· Gender;

· Address;

· Email address;

· Telephone number;

· Job title;

· Profession;

· Information about your preferences and interests;

· Information as disclosed by you during telephone and/or written and/or electronic communications with the Company;

· Details of ethnic background for equality management & assurance purposes;

· Payment, wage and salary information;

· Health information disclosed in accordance with accident reporting and/or in association with similar matters;

· Medical and/or health and/or disability records/details; in connection with welfare, equality, capabilities, Health & Safety, and general HR management;

· Sickness records, including medical statements and/or fit-notes and/or medical practitioner communications (telephone and/or written and/or electronic); in connection with welfare, equality, capabilities, Health & Safety, and general HR management;

· Employment records, including third party references, in connection with general employment legislation and personnel/HR management;

· Disciplinary and Grievance records, in connection with general employment legislation and personnel/HR management;

· Performance records and similar data, in connection with general employment legislation and/or personnel/HR management and/or quality assurance;

· Attendance records, which may include details of any absence, in connection with general employment and/or personnel/HR management;

· Details of Trade Union membership, in connection with general employment and/or personnel/HR management;

· Details of criminal records;

· Education details, as provided by employees (or candidates) in connection with personnel / HR management;

· Other documentation as provided by you in connection with ID verification purposes;

· Copy passport and/or driving licence, in connection with ID verification purposes and/or verification of entitlement to drive Company vehicles (or other vehicles that you may be required to drive during the course of your employment);

· Photographic images of you, for identification purposes, including (but not restricted to) the production and Company (and sometimes Customer) ID badges;

· Employment details, general and specific, in connection with personnel and/or HR management, equality and employment legislation;

· Details of debts resulting in Court Order (attachment of earnings order, or similar) that require a deduction from wages;

· Details of child support payments requiring deduction from earnings, etc;

· Bank account details.

 

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data.  This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.  Your personal data may be used for one or more of the following purposes:

· Provision of employment contract(s).  Your personal details are required in order for us to enter into a contract with you;

· Providing and managing your employment and associated records;

· Managing your pay, wages, salaries, deductions and associated records;

· Management of pension schemes;

· Assessing your capabilities;

· Performance management and managing Quality Assurance;

· Staff welfare management;

· Management of Health and Safety or similar legislation; to include training;

· Equality training and management;

· Considering suitability for post;

· Consideration and/or provision of reasonable adjustments;

· Training and Quality Assurance purposes;

· Customer service management;

· Management of personnel systems and/or HR matters;

· Management of disciplinary and/or grievance processes and procedures;

· Responding to emergencies directly involving you;

· Responding to emergencies on Customer premises (or any other location) that may involve you directly or indirectly;

· General business and/or service and/or supply management;

· Communicating with you.  This may include responding to emails or calls from you;  

· Supplying our products and/or services to you, in the event that you also enter a Customer relationship with the Company – in this case please also see  BCS’ Customer Privacy Policy; personalising and tailoring our products and/or services for you;

· Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by writing to DPO Duty Holder at the address shown under Part 1, or by emailing dpo@bcsonline.org.uk and quoting “opt-out” in the email subject.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services.  You will not be sent any unlawful marketing or spam.  We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

 

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.  Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

· The duration of fulfilment of contract and/or for the purposes at hand, plus retention period (ordinarily six years), and/or six financial years from point of audit of the period pertaining to the data (whichever is the greater);

· There are some instances where data may need to be kept for significantly longer periods of time, such instances include (but are not limited to) certain health & safety matters (for instance matters relating to hazardous substances) that may require permanent record, etc.

· To uphold data assurance principles, each dataset shall be considered and reviewed upon its own merits, where longer data retention is required.

 

8. How and Where Do You Store or Transfer My Personal Data?

Predominantly we will only store or transfer your personal data within the European Economic Area (the “EEA”).  The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein.  This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

However, we may also store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein).  These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA.  This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.

We may also transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield.  This requires that third party to provide data protection to standards similar levels of data protection to those in Europe.  More information is available from the European Commission.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

· Data access restricted to authorised personnel only;

· Data encryption;

· Avoidance of use of USB-stick flash drives; where such flash drives (or similar) are used, your data is encrypted.

· Encryption of Company data backups.

· Predominantly, and so far as is reasonably practicable, data is stored on the Company’s own server (utilising drive encryption).

· Use of antivirus software.

· VPN connection for remote data access; whilst such network connections shall necessarily utilise third party software, so far as is reasonably practicable such network connections shall not rely on third party services.

· GDPR compliant contracts, or similar data integrity assurances, with service partners and third parties;

· Secure deletion of data, utilising multi-pass deletion of digital data from hard drives, shredding CDs / DVDs housing digital data, shredding of paper records to P-4 standards.

 

9. Do You Share My Personal Data?

We may sometimes contract with third parties to supply products and/or services to you on our behalf, or to provide/manage any aspect of the Company’s administration and/or management.  These may include, but are not restricted to, payment processing, credit control, accounts management, delivery, marketing, electronic communications transfer and/or exchange, customer services, telephony services and/or telephony recording services, voicemail services, quality assurance, personnel and human resources management, health and safety management, processing of insurance-related matters, DBS enquiries and processing, pensions processing, welfare at work issues, conciliation and/or mediation processes.  In some cases, those third parties may require access to some or all of your personal data that we hold.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

 

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held).  This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.  To make this as easy as possible for you, a Subject Access Request Form is available for you to use.  You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request.  If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one calendar month of receiving it.  Normally, we aim to provide a complete response, including a copy of your personal data within that time.  In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.  You will be kept fully informed of our progress.

 

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details:

Data Protection Post Holder

Email: dpo@bcsonline.org.uk

Telephone: 01268 492 800.

Postal Address:  BCS, Jubilee House, 3 The Drive, Great Warley,

                            Brentwood, Essex, CM13 3FR.

 

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time.  This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available via www.bcsonline.org.uk and/or email and/or postal services.

 

 

 

Back to Top

 

 

01268

492 800