1. What is the purpose of this document?
1.1 Klean Keepers Ltd are a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy notice because your details have been obtained either directly from your submission to an advertised role, through you registering on our website or through a referrer of candidates such as a job board. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment and contracting exercise, 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).
2. Data protection principles
2.1 We will comply with data protection law and principles, which means that your data will be:
(a) Used lawfully, fairly and in a transparent way.
(b) Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
(c) Relevant to the purposes we have told you about and limited only to those purposes.
(d) Accurate and kept up to date.
(e) Kept only as long as necessary for the purposes we have told you about.
(f) Kept securely.
3. The kind of information we hold about you
3.1 We will collect, store, and use the following categories of personal information about you:
(a) The information you have provided to us in your curriculum vitae and any covering letter.
(b) The information you have provided , including name, title, address, telephone number, personal email address, and work email address.
4. How is your personal information collected?
4.1 We may collect personal information about clients or prospects s from the following sources:
(b) Referrals, such as the details of people you know have passed the information on to us requiring our services.
(c) From third parties who are, for example, a publicly accessible source such as the world wide web, or who have provided your information to Klean Keepers Ltd.
5. How we will use information about you
5.1 We need all the categories of information in the list above primarily to allow us to provide cleaning and maintenance services for you, perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
(a) Informing you by phone or electronic mail on promotions or information on our services.
(b) Business management and planning, including accounting and auditing.
(c) To conduct data analytics.
5.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
6. If you fail to provide personal information
6.1 If you fail to provide information when requested, which is necessary for us to provide you with a price quotation or any service, we will not be able to process your information on to you successfully. Similarly, we may be unable to perform any contract we enter into with you.
7. Change of purpose
7.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. How we use particularly sensitive personal information
8.1 “Special categories" of particularly sensitive personal information require higher levels of protection. We have put in place appropriate safeguards which we are required by law to maintain when processing such data however we need to have further justification for collecting, storing and using this type of personal information. With this in mind we may process special categories of personal information in the following circumstances:
(a) In limited circumstances, with your explicit written consent.
(b) Where we need to carry out our legal obligations or exercise rights in connection with employment laws.
(c) Where it is needed in the public interest.
8.2 Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about candidates or former candidates in the course of legitimate business activities with the appropriate safeguards.
8.3 We will use your particularly sensitive personal information in the following ways:
(a) We will use information about your disability status to consider whether we need to provide appropriate adjustments during the contracting process, for example whether adjustments need to be made.
9. Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us
10. Automated decision-making
11.1 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
12. Data sharing
12.1 We will only share your personal information with third parties after obtaining your consent to do so, for the purposes of processing your application for work and for undertaking a contract we have with you, such as passing your information on to any hirer. At the point of obtaining your consent, we will disclose to you the third parties your personal information will be shared with.
13. Data security
13.1 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 and contractors 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.
13.2 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.
14. Data retention
14.1 We will retain your personal information for a period of 5 years from the date:
(a) We receive your details a referrer
(b) We receive your contact details from an advertisement
(c) You register through our Website
(d) Whichever is longer.
14.2 We retain your personal information for this period on the basis that a further opportunity may arise in future and we may wish to consider you for that, so that we can show that you may consider using our services and that we have also conducted ourselves in a fair and transparent way, so we can comply with our requirements to keep records for legal purposes, such as pay records, and in the event of a legal claim. After this period, unless separately legally required to retain the information, we will securely destroy your personal information in accordance with our data retention policy and the applicable laws and regulations.
14.3 If we wish to retain your personal information on file for a period beyond the above, we will write to you separately, seeking your explicit consent to retain your personal information for a further fixed period on that basis. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
15. Rights of access, correction, erasure, and restriction
15.1 Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
(a) 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.
(b) 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.
(c) 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).
(d) 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.
(e) 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.
(f) 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 our data protection officer (DPO) in writing as set out below.
16. Data protection officer
16.1 We have appointed a data protection officer (DPO) Basel Sharaf 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 our DPO by emailing Basel Sharaf at firstname.lastname@example.org 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.