We are an employment business which seeks to find individuals work with our hirer clients, and provides the services of workers we have engaged (Workers) to the hirer.
We will process your personal data as a “data controller”. This means that we have responsibility (on our own or acting jointly with another party) for deciding how we hold and use personal data relating to you.
2. Who we are and how to contact us
Hive Hospitality Ltd (Company, We, us, our) is a limited company registered in England and Wales under company number 11027926 and has its registered address at Burnden House, Bolton, BL3 2RR.
Our Data Protection Officer is Saj Ahmed and can be contacted at firstname.lastname@example.org or on 0161 302 7972.
3. The data we collect and process about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• [Identity Data including Name, Title, date of birth, nationality, gender]
• [Contact Data including Postal address, email address, telephone numbers]
• [Worker Status Data including visa information and information relating to your right to work in the UK]
• [Payroll and PAYE Data including bank details, information relating to hours worked, rate of pay, tax code, unique tax reference number, National Insurance number.]
4. How we collect personal data
We may obtain your personal data directly from you (e.g. in a Curriculum Vitae, application or registration form, via our website, or in correspondence, a meeting or telephone call), a hirer, the third party company we engage to provide payroll and administration services on our behalf, or online jobsites, public domain, former employers.
5. How and why we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• 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 it is necessary to comply with a legal or regulatory obligation that we are subject to.
We have set out in the table below a description of the ways we may use your personal data, and the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground applies.
|Purpose/Activity||Types of data||Lawful basis for processing including basis of legitimate interest|
|Setting you up as a new Worker on our systems||Identity Data, Contact Data, Worker Status Data||Performance of a contract with the data subject|
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Sensitive personal data
[We do not intend to collect any “special categories of personal data” (such as information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin or information relating to your health). However, to the extent that you do provide us with any special categories of data, we will only use that data for the purposes of our relationship with you and providing our recruitment services to you. This may be for one or more of the following reasons:
• with your explicit consent (in limited circumstances);
• where we need to carry out our legal obligations or exercise rights in connection with employment;
• where the processing is necessary for the purposes of preventive or occupational medicine or for assessing your working capacity;
• where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.]
7. If you fail to provide personal data
Where we need to collect personal data by law or in order to perform a contract to which you are a party, and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel the contract, but we will notify you if this is the case at the time.
8. Disclosures of your personal data
We may share personal data with hirers or other third parties in connection with the provision of our recruitment services.
We may also disclose personal data to:
• third party service providers who process data on our behalf, such as:
• outsourced payroll services;
• IT support
• professional advisers including lawyers, bankers, auditors and insurers for the purpose of providing consultancy, banking, legal, insurance and accounting services to us;
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
We require all our data processors to respect the security of your personal data and to treat it in accordance with the law. We do not allow our data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
10. Data security
We have put in place security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
11. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
12. Your rights in respect of your personal data
You have certain rights in respect of the personal data that we process about you (where we determine the purpose and means for which that personal data shall be processed):
• the right to request access to the personal data that we hold about you and how we process it;
• you may have the right in accordance with applicable data protection law to have personal data we hold about you rectified or restricted;
• you may, in some circumstances, have the right to have personal data we hold about you deleted (although note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request);
• in some circumstances, you may have the right to receive or ask for your personal data to be transferred to a third party;
• you have the right to object to how we process your personal data where that processing is based upon legitimate interests and there are no compelling grounds for the continued processing of that data;
• where we are processing personal data relating to you on the basis that we have your consent to do so, you may withdraw your consent at any time (this will not affect the lawfulness of any processing carried out before you withdraw your consent). If you withdraw your consent, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above in respect of your personal data, please contact us at email@example.com.
We may ask you to verify your identity if you make a request to us to exercise any of the rights set out above. We may also contact you to ask you for further information in relation to your request to speed up our response. 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.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.