DISCLOSURE

Paul Holman Associates Ltd may share data with other agencies such as the local authority, funding bodies and other voluntary agencies.

The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows Paul Holman Associates Ltd to disclose data (including sensitive data) without the data subject’s consent.

These are:

1. Carrying out a legal duty or as authorised by the Secretary of State
2. Protecting vital interests of a Individual/Service User or other person
3. The Individual/Service User has already made the information public
4. Conducting any legal proceedings, obtaining legal advice or defending any legal rights
5. Monitoring for equal opportunities purposes – i.e. race, disability or religion
6. Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
7. Paul Holman Associates Ltd regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.

Paul Holman Associates Ltd intends to ensure that personal information is treated lawfully and correctly.

To this end, Paul Holman Associates Ltd will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998.

Specifically, the Principles require that personal information:

1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
2. Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
3. Shall be adequate, relevant and not excessive in relation to those purpose(s)
4. Shall be accurate and, where necessary, kept up to date
5. Shall not be kept for longer than is necessary
6. Shall be processed in accordance with the rights of data subjects under the Act,
7. Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
8. Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.

Paul Holman Associates Ltd will, through appropriate management and strict application of criteria and controls:

• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:
  • The right to be informed that processing is being undertaken,
  • The right of access to one’s personal information
  • The right to prevent processing in certain circumstances and
  • The right to correct, rectify, block or erase information which is regarded as wrong information)
• Take appropriate technical and organisational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information

COLLECTING YOUR DATA

You provide several pieces of data to us directly during any agreement negotiation period, for example your name and address, and subsequently for example, your bank details.

In some cases we will collect data about you from third parties, such as intermediaries and agents who may act as an introducer.

Personal data is kept within the Company’s HR & IT systems and online secure Portal.

LAWFUL BASIS FOR PROCESSING

The data protection law allows us to process your data for certain reasons only. Primarily, to comply with a legal requirement, in order to perform the contract we have with you or in pursuit of our legitimate interests.

The below table categorises the types of data processing we undertake and the lawful basis we rely upon.

SPECIAL CATEGORIES OF DATA

Special categories of data are those relating to your:

1. Health
2. Sex life
3. Sexual orientation
4. Race
5. Ethnic Origin
6. Political Opinion
7. Religion
8. Trade Union Membership
9. Genetic & Biometric Data

We will process special categories of data in the following situations:

1. You have given explicit consent to the processing
2. We must process the data in order ot carry out our legal obligations
3. We must process data for reasons of substantial public interest
4. You have already made the data public

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

FAILURE TO PROVIDE DATA

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract with you or performing the contract that we have entered into.

CRIMINAL CONVICTION DATA

We will only collect criminal conviction data where it is appropriate given the nature of the services you are to provide to us and where the law permits us. This data will usually be collected during contract negotiation, however, may also be collected during your engagement. We use criminal conviction data to determine your suitability, or your continued suitability for the engagement. We rely on the lawful basis of our legitimate interests to process this data.

WHO WE SHARE YOUR DATA WITH

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out of performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR.

Data is shared with third parties for the following reasons: for the administration of payroll.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

DATA STORAGE

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers. Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is Paul Holman Associates Ltd responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

CONSENT

Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.

COMPLIANCE

In case of any queries or questions in relation to this policy please contact the Paul Holman Associates Ltd Data Protection Officer:

Paul Holman
Morritt House
58 Station Approach
South Ruislip
Middlesex
HA4 6SR

T: 020 8845 9408
E: paul@paulholmanassociates.co.uk