LP Employment & Training Services Limited incorporated and registered in England and Wales with company number 5891080 whose registered office is at Arena Point, Merrion Way, Leeds, LS2 8PA (‘the Company’)
Company Data Protection Contact Details:
Jamie Mclean, Data Protection Officer, Arena Point, Merrion Way, Leeds, LS2 8PA or email [email protected]
Topic: Data Protection (to incorporate GDPR)
Date: Wednesday 10th March 2021
Version: Version 1
The Company is a Training Provider which provides Training, Workfinding, and Health, Drug and Alcohol Screening to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via a website, or we may collect them from another sources such as a A jobs board, applicant tracking system or other online media channel. The Company must have a legal basis for processing your personal data.
For the purposes of providing you with Training, Workfinding or Health, Drug and Alcohol Screening and/or information relating to roles and/or relevant to you we will only use your personal data in accordance with the terms of the following statement.
1.Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with Training, Workfinding or Health, Drug and Alcohol Screening. This includes for example, contacting you about, training, job opportunities, assessing your health and/or suitability for those opportunities, updating our database, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
This includes the processing of personal data for the purposes of administering, managing and employing staff and workers, including those engaged via a Limited Company, Sub-Contract or Intermediary. This includes: payroll, benefits, medical records, absence records, sick leave/pay information, performance reviews, disciplinary and grievance matters, pension provision, recruitment and professional development (including qualifications and training records), family policies (maternity, paternity, adoption etc) and equal opportunity monitoring.
In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
The legal bases we rely upon to offer these services to you are:
• Your consent
• Where we have a legitimate interest
• To comply with a legal obligation that we have
• To fulfil a contractual obligation that we have with you
b. Legitimate Interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
• Managing your database entry and keeping records up to date;
• Contacting the individual to seek your consent where you need it;
• Providing Training, Workfinding or Health, Drug and Alcohol Screening to the individual, including sending their information to your clients where they have demonstrated an interest in doing that particular type of work but not expressly consented to you passing on their details;
• Contacting the individual with information about similar products or services that they have used from you recently; and
• Passing work-seeker’s information to intermediaries.
• Providing training and testing services.
• Medical and Health assessment services.
c. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
• Financial organisations
• Current, past or prospective employers
• Education and training providers and their examining bodies
• Suppliers and service providers
• Central government
• Credit reference agencies
• Debt collection and tracing agencies
• Business associates
• Complainants and enquirers
• Professional advisers and consultants (Including medical and health professionals)
d. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
The Company may not be able to provide Training, Workfinding or Health, Drug and Alcohol Screening to a client or discharge it’s legal responsibilities.
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
Health and Medical Records will be held in accordance with the guidelines set out by the HSE and will be retained in a suitable form for at least 40 years from the date of last entry.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
As the Company has obtained your consent to process your personal data we will do so in line with our retention policy a copy of which is available from the Data Processing Office. Upon expiry of that period the Company may seek further consent from you. Where consent is not granted the Company will cease to process your data.
Please be aware that you have the following data protection rights:
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
Where you have consented to the Company processing your data you have the right to withdraw that consent at any time by contacting the Data Protection Officer.
There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
In a situation where the Company should act jointly with other organisations as a controller, then respective responsibilities will be clearly laid out between the parties.
6.Source of the personal data
The Company sourced your personal data/sensitive personal data by the following means:
• Application or registration form or via our website.
• A jobs board, applicant tracking system or other online media channel
• The Government’s ‘Find a job’ service previously known as Universal Jobmatch.
• Referral via a Third-Party Associate and/or a company of LOGICAL PS GROUP LIMITED
This information may not have come from a publicly accessible source.
7.Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Jamie Mclean, Data Protection Officer, Arena Point, Merrion Way, Leeds, LS2 8PA or email [email protected]
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to. The company are registered with the Information Commissioners Office (ICO) under Registration Number ZA787069, details of the Scope of Registration can be access via this link: https://ico.org.uk/ESDWebPages/Entry/ZA787069