This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.signposthrsolutions.co.uk, including any information you may provide through our site when you purchase a product or service or sign up to our newsletter.
Signpost HR Solutions Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Full name of legal entity: Signpost HR Solutions Ltd
Contact point: Rosemary Darby-Jenkins, Director
Postal address: 42 Sopers Lane, Christchurch, Dorset BH23 1JF
If you are unhappy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint, so that we can try to resolve it for you.
2. WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
• Identity Data may include your first name, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by subscribing to our newsletter through our website or by communicating with us by post, phone, email or otherwise, including when you:
• request our products or services
• subscribe to our service or newsletters;
• request resources to be sent to you;
• give us feedback.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Xero Limited
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted:
Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
Type of data
Lawful basis for processing
To register you as a new customer
Performance of a contract with you
To process and deliver our services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated.
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about goods or services that may be of interest to you or to send you our newsletter.
Necessary for our legitimate interests to develop our products/services and grow our business.
You will receive marketing communications from us if you have:
(i) requested information from us or purchased services from us; or
(ii) if you subscribed to our newsletter on our website and
(iii) in each case, you have not opted out of receiving that marketing.
We do not share your personal data with any third party for marketing purposes.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
Change of purpose
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.