This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during your employment or engagement as a self-employed linguist or other contractor and after it ends. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
WHO COLLECTS THE INFORMATION
D A Languages Limited (the Company) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, (our group companies) and so, in this notice, references to ‘we’ or ‘us’ mean the Company and our group companies.
DATA PROTECTION PRINCIPLES
We will comply with the data protection principles when gathering and using personal information, as set out in our data protection (employment) policy.
ABOUT THE INFORMATION WE COLLECT AND HOLD
We may collect the following information during your employment/engagement:
Certain of the categories above may not apply to you if you are an independent contractor.
HOW WE COLLECT THE INFORMATION
We may collect this information from you, your personnel records, the Home Office, pension administrators, your doctors, from medical and occupational health professionals we engage and from our insurance benefit administrators, the DBS, other employees, consultants and other professionals we may engage, eg to advise us generally and/or in relation to any grievance, conduct appraisal or performance review procedure, door entry systems, swipe card systems, time management system, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, remote access systems, email and instant messaging systems, intranet and Internet facilities, telephones, voicemail,
WHY WE COLLECT THE INFORMATION AND HOW WE USE IT
We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our data protection policy (employees)):
HOW WE USE SENSITIVE PERSONAL INFORMATION
“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
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
HOW WE MAY SHARE THE INFORMATION
We may also need to share some of the above categories of personal information with other parties, such as external contractors and our professional advisers and with potential purchasers of some or all of our business or on a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law.
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: HR advice, occupational health assessments, pension administration, service provision messaging.
WHERE INFORMATION MAY BE HELD
Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above. Information may be transferred internationally to other countries around the world, including countries that do not have data protection laws equivalent to those in the UK, for the reasons described above. We have security measures in place to seek to ensure that there is appropriate security for information we hold including those measures detailed in our data protection policy (employment).
INTERNATIONAL DATA TRANSFERS
Whenever we transfer your personal data out of the United Kingdom (UK) or European Economic Area (EEA), we ensure it is done so in accordance with the relevant data protection legislation. Where the third country does not have an adequacy decision we will put in measures ensure that your personal data is protected.
HOW LONG WE KEEP YOUR INFORMATION
We keep your information during and after your employment/engagement for no longer than is necessary for the purposes for which the personal information is processed. Further details on this are available in our data protection (employment) and data retention policies.
YOUR RIGHT TO OBJECT TO US PROCESSING YOUR INFORMATION
Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Please contact our data protection officer, who can be contacted DPO@dalanguages.co.uk if you wish to object in this way.
YOUR RIGHTS TO CORRECT AND ACCESS YOUR INFORMATION AND TO ASK FOR IT TO BE ERASED
Please contact our data protection officer, who can be contacted at DPO@dalanguages.co.uk if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our data protection officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our data protection officer will provide you with further information about the right to be forgotten, if you ask for it.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
We hope that our data protection officer can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.