PRIVACY POLICY
BY USING OUR WEBSITE OR USING OUR SERVICES AND GIVING YOUR INFORMATION
TO US, YOU INDICATE THAT YOU UNDERSTAND HOW WE WILL USE AND PROTECT
YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY
BACKGROUND:
People Based Solutions Ltd understands that your privacy is important to you and that you
care about how your personal data is used and shared online. We respect and value the
privacy of everyone who visits this website, www.peoplebasedhr.co.uk (“our Site”) and will only
collect and use personal data in ways that are described here, and in a manner that is
consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance
of our Privacy Policy is deemed to occur upon you enquiring about or entering into a contract
for one or more of our Services and your first use of our Site, which you must stop using
immediately if you do not accept and agree with this Privacy Policy.
If you provide information about any other person other than yourself, you must ensure that
they understand how their information will be used and that you are authorised to disclose it to
us, and to consent to its use on their behalf before doing so.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Company” “The Company” means People Based Solutions Ltd., a
limited company registered in England under company
number 08065344, whose registered address is Dallam
Court, Dallam Lane, Warrington, Cheshire, WA2 7LT.
“Site” means our website, www.peoplebasedhr.co.uk
and any landing pages or pages created by us on any
social media platforms which direct you to our Site.
“Services” means one or more of the online services we provide
including our HR database, server, document
management systems and Help Desk as well as our
Portal.
“Portal” means our dedicated portal for securely uploading and
downloading documentation
“Account” means an account required to access and/or use certain
areas and features of our Site;
“Cookie” means a small text file placed on your computer or
device by our Site when you visit certain parts of our
Site and/or when you use certain features of our Site.
Details of the Cookies used by our Site are set out in
section 13, below and you can see how we use cookies
in our Cookie Policy;
“personal data” “Personal data” means any information relating
to an identifiable natural person who can be
directly or indirectly identified from that
information (‘the data subject”). This definition
shall, where applicable, incorporate the
definitions provided in the “GDPR”; and in this
case, it applies to personal data disclosed to the
Company for the purposes of managing the
provision of its services.
“Special category” personal data (also known as
“sensitive” personal data). Such data includes, but is not
necessarily limited to, data concerning the data
subject’s race, ethnicity, politics, religion, trade union
membership,
“Privacy Laws” means all applicable privacy and
data protection laws including the EU
Regulations, General Data Protection
Regulation (“GDPR”) and the Privacy and
Electronic Communications (EC Directive)
Regulation 2003 (as amended), together with
the Data Protection Act 2018 and all subordinate
legislation, directions of any competent privacy
regulator, common law and other relevant court
decisions and all relevant privacy and/or data
protection codes of practice in each case as may
be amended or replaced from time to time.
“Third Parties” are under the direct authority of
the Data Controller and are authorised to
process personal data on behalf of the Data
Controller. They include, but are not limited to:
business contacts, contractors and service
providers. Please paragraph 2 for details of our
Third Parties.
2. Information About Us and Third Parties
2.1 Our VAT number is 153994572.
2.2 Our Data Protection Officer is Sean McCann, and can be contacted by email at
smccann@peoplebasedsolutions.com, by telephone on 01925 525957, or by
post at Dallam Court, Dallam Lane, Warrington, Cheshire, WA2 7LT.]
2.3 We are a member of the Chartered Institute of Personnel Development.
2.4 Our Site is operated by Techniframe Ltd., a limited company registered in
England under company number 08936951, whose registered address is
Ashland House, Dobson Park Way, Ince in Makerfield, Wigan, WN2 2DX and
whose main trading address is Ashland House, Dobson Park Way, Ince in
Makerfield, Wigan, WN2 2DX.
2.5 Our Site is hosted in the European Union by 123 Reg Ltd, a limited company
registered in England under company number 05306504, 5th Floor, The
Shipping Building Old Vinyl Factory, 252-254 Blyth Road, Hayes, Middlesex,
UB3 1HA
2.6 Our Site undergoes analytics services performed by Google Analytics…
2.7 Our Electronic contracts stored online in our CRM system which is hosted
hosted within the European Union by 123 Reg.
2.8 Our client and supplier financial information operated by Quickbooks Online, a
limited company registered in England under company number, 2679414,
whose registered address is 1 Cathedral Piazza, London, SW1E 5BP and is
hosted within the European Union.
2.9 Our employee payroll information help and is processed by AIMS accountancy
services, a limited company registered in England under company number,
02740695, whose registered address is 3 Park Road, London, NW1 6AS and
is hosted within the European Union.
3. What Does This Policy Cover?
This Privacy Policy applies to:
3.1 your use of our Site. Our Site may contain links to other websites. Please note that
We have no control over how your data is collected, stored, or used by other websites
and We advise you to check the privacy policies of any such websites before providing
any data to them.
3.2 your enquiry into or use of one or more of our Services. The provision of our
Services may require the services of third parties listed in section 2. Whilst we have
made every effort to verify the data protection procedures of these third parties, we
advise you check their Privacy Policies before engaging our Services.
4. Your are your Rights?
4.1 As a data subject, you have the following rights under the GDPR, which this
Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section
12);
4.1.3 The right to rectification if any personal data We hold about you is
inaccurate or incomplete (please contact Us using the details in section
14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal
data We hold about you (We only hold your personal data for a limited
time, as explained in section 6 but if you would like Us to delete it sooner,
please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to reuse with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes;
and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about our use of your personal data, please
contact us using the details provided in section 14 and we will do our best to
solve the problem for you. If we are unable to help, you also have the right to
lodge a complaint with the UK’s supervisory authority, the Information
Commissioner’s Office.
4.3 For further information about your rights, please contact the Information
Commissioner’s Office or your local Citizens Advice Bureau.]
5. What Data Do We Collect and How?
In order to provide you with the Services you require we may collect your data when
communicating with you via email, text message, instant messaging, telephone calls,
post or otherwise, including cookies on our Site, (please also see section 13 on our use
of Cookies and similar technologies).
We collect some or all of the following personal and non-personal data:
5.1 name;
5.2 business/company name
5.3 job title;
5.4 profession;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences and interests;
5.7 IP address;
6. How Do We Use Your Data?
6.1 We keep and use your personal data in the form of your contact details when
you use our services. To maintain the quality of our services, we will also keep
and use records of the nature and contact we have with you and the services
we have provided. We may, from time to time use this information in order to
tailor Our services and inform you of ways we can help. You may on occasion
provide us with documentation and information relevant to issues we are
advising on. We will retain and use this information to enable us to provide the
relevant service to you. We will not disclose any information about individuals
from except where We are required by law to do so. For more details on how
we share your data, see section 8, below.
6.2 All personal data is processed and stored securely, for no longer than is
necessary for fulfilling the purposes for which it was first collected and not further
processed in a manner that is incompatible with those purposes. We will comply
with Our obligations and safeguard your rights under the GDPR at all times. For
more details on security see section 7, below.
6.3 Our use of your personal data will always be lawful, either because it is
necessary for Our fulfilment of a contract with you, because you have consented
to Our use of your personal data (e.g. by subscribing to newsletters), or because
it is in Our legitimate interests. Specifically, We may use your data:
6.3.1 For registration and general administration of your Account (including
verification, vetting and security checking);
6.3.2 To provide and administer the products and services you request from
Us and any Account you have with Us (which will include tracing and
collecting debts and fraud prevention);
6.3.3 To provide and manage your access to Our Site;
6.3.4 To communicate with you in the event that any services requested are
unavailable or if there is a query with you requests;
6.3.5 To carry out market research so that we can improve the goods and
services we offer;
6.3.6 To personalise and tailor Our products and services to you;
6.3.7 To track and analyse activity on Our Site
6.3.8 To personalise and tailor your experience on Our Site and respect your
preferences; and
6.3.9 For record keeping purposes.
6.4 With your permission and/or where permitted by law, We may also use your
data for marketing purposes which may include contacting you by email,
telephone, text message, instant messaging or post with information, news
and offers on Our products and services. We will not, however, send you any
unsolicited marketing or spam and will take all reasonable steps to ensure that
We fully protect your rights and comply with Our obligations under the Privacy
Laws.
6.5 You can withdraw your consent to Us using your personal data for direct
marketing purposes at any time, and request that We delete it. To opt-out of
receiving direct marketing you can contact
enquiries@peoplebasedsolution.co.uk
6.6 We will continue to use your data in order to fulfil our contract with you and/or
where we have a legitimate interest to do so. Without the use of your personal
data we will be unable to proceed with the provision of Our services.
6.7 We will not keep your personal data for any longer than is necessary for fulfilling
the purpose for which it was first collected, nor further process your personal
data in a manner that is incompatible with those purposes. We will determine
the retention period for your personal data on the following bases:
6.7.1 If We, you or your employer terminates the contract for Our services, or
your job role no longer requires you to use Our services, you will be
entitled to access Our services for three months from the point at which
the contract is terminated or We are notified that access is no longer
required.
6.7.2 If you are a prospective client We will not keep your details for longer
than 12 months from the date on which you submit your data to us for
the purposes of entering into a contract;
6.7.3 If you have submitted your personal data for Us to use for direct
marketing purposes, we will hold your personal data on our suppression
list and cease all further direct marketing to you; or comply with your
request to exercise your right to erasure (‘to be forgotten’).
7. How and Where Do We Store Your Personal Data?
7.1 We only keep your personal data for as long as We need to in order to use it as
described above in section 6, and/or for as long as We have your consent to
keep it.
7.2 Your personal data will only be stored within the European Economic Area (“the
EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and
Liechtenstein).
7.3 Data security is extremely important to Us, and to protect your data We have
taken all necessary measures to safeguard and secure data collected through
Our online services and Our Site. For further information on the technical and
organisational measures we have taken, please refer to Our Data Protection
Policy.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your personal data with any third
parties for any purposes other than when it is necessary for the performance of
Our contract to provide Our Services to you.
8.2 In certain circumstances, We may be legally required to share certain data
held by Us, which may include your personal data, for example, where We are
involved in legal proceedings, where We are complying with legal obligations,
we are compelled to do so by a court order, or we are required to disclose
your personal data to a governmental authority.
8.3 We may compile statistics about the use of Our Site including data on traffic,
usage patterns, user numbers, sales, and other information. All such data will
be anonymised and will not include any personally identifying data, or any
anonymised data that can be combined with other data and used to identify you.
We may from time to time share such data with third parties such as prospective
investors, affiliates, partners, and advertisers. Data will only be shared and used
within the bounds of the law.
9. What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve
the sale and/or the transfer of control of all or part of Our business. Any personal
data that you have provided will, where it is relevant to any part of Our business
that is being transferred, be transferred along with that part and the new owner
or newly controlling party will, under the terms of this Privacy Policy, be
permitted to use that data only for the same purposes for which it was originally
collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will
not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit
personal data via Our Site, you may be given options to restrict Our use of your
data. In particular, We aim to give you strong controls on Our use of your data
for direct marketing purposes (including the ability to opt-out of receiving emails
from Us which you may do by unsubscribing using the links provided in Our
emails).
10.2 You may also wish to sign up to one or more of the preference services
operating in the UK which block companies from sending you unsolicited direct
marketing. They are: the Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). Please note, however, that these services will
not prevent you from receiving marketing communications that you have
positively opted-in to receive.
11. Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all.
However, to use all features and functions available on Our Site you may be
required to submit or allow for the collection of certain data.
11.2 You may restrict Our use of Cookies. For more information, see section 13
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where
such data is held). Under the GDPR, no fee is payable and We will provide any and all
information in response to your request free of charge. Please contact Us for more
details at enquiries@peoplebasedsolutions.co.uk or using the contact details below in
section 14.
13. [Our Use of Cookies
13.1 Our Site may place and access certain first party Cookies on your computer or
device. First party Cookies are those placed directly by Us and are used only
by Us. We use Cookies to facilitate and improve your experience of Our Site
and to provide and improve our Services. We have carefully chosen these
Cookies and have taken steps to ensure that your privacy and personal data
are protected and respected at all times.
13.2 All Cookies used on Our Site are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a pop
up requesting your consent to set those Cookies. By giving your consent to the
placing of Cookies you are enabling Us to provide the best possible experience
and service to you. You may, if you wish, deny consent to the placing of
Cookies; however certain features of Our Site may not function fully or as
intended.
13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems
these Cookies to be “strictly necessary”. These Cookies are shown below in
section 13.5. Your consent will not be sought to place these Cookies, but it is
still important that you are aware of them. You may still block these Cookies by
changing your internet browser’s settings as detailed below in section 13.9, but
please be aware that Our Site may not work properly if you do so. We have
taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following first party Cookies may be placed on your computer or device:
Name of Cookie Purpose Strictly Necessary
_pk_id.49.44d9 To allow connection Yes
catAccCookies Record that the user accepts the fact that
the site uses cookies.
Yes
ms-session Allows the user proceed through many
pages of a site quickly and easily without
having to authenticate or reprocess each
new area they visit.
Yes
ms-uid To facilitate browsing Yes
wp-settings This is used to customize the user’s view of
admin interface, and possibly also the main
site interface.
Yes
wp-settings-time This is used to customize the user’s view of
admin interface, and possibly also the main
site interface.
Yes
13.6 Our Site uses analytics services provided by Google Analytics. Website
analytics refers to a set of tools used to collect and analyse anonymous usage
information, enabling Us to better understand how Our Site is used. This, in turn,
enables Us to improve Our Site and the services offered through it. You do not
have to allow Us to use these Cookies, however whilst Our use of them does
not pose any risk to your privacy or your safe use of Our Site, it does enable Us
to continually improve Our Site, making it a better and more useful experience
for you.
13.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required
information.
13.8 The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie First / Third
Party
Provider Purpose
ga third Google Expires after 2 years is
Used to distinguish users
_gid third Google Expires after 24 hours is
Used to distinguish users
_gat third Google Expires after 1 minute. Used
to throttle request rate. If
Google Analytics is deployed
via Google Tag Manager, this
cookie will be named
_dc_gtm_<property-id>.
AMP_TOKEN third Google Expires after 30 seconds to 1
year. Contains a token that can
be used to retrieve a Client ID
from AMP Client ID service.
Other possible values indicate
opt-out, inflight request or an
error retrieving a Client ID from
AMP Client ID service.
_gac_<property-id> third Google Expires after 90 days. Contains
campaign related information.
13.9 In addition to the controls that We provide, you can choose to enable or disable
Cookies in your internet browser. Most internet browsers also enable you to
choose whether you wish to disable all cookies or only third party cookies. By
default, most internet browsers accept Cookies but this can be changed. For
further details, please consult the help menu in your internet browser or the
documentation that came with your device.
13.10 You can choose to delete Cookies on your computer or device at any time,
however you may lose any information that enables you to access Our Site more
quickly and efficiently including, but not limited to, login and personalisation
settings.
13.11 It is recommended that you keep your internet browser and operating system
up-to-date and that you consult the help and guidance provided by the
developer of your internet browser and manufacturer of your computer or device
if you are unsure about adjusting your privacy settings.
13.12 For further information on cookie and Flash cookies and how to switch them off
see the Information Commissioner’s website at www.ico.org.uk or visit
www.allaboutcookies.org or www.aboutcookies.org
14. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by
email at enquiries@peoplebasedsolutions.co.uk, by telephone on 01925 525 957, or
by post at Dallam Court, Dallam Lane, Warrington, Cheshire, WA2 7LT. Please ensure
that your query is clear, particularly if it is a request for information about the data We
hold about you (as under section 12, above).
15. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the applicable
privacy laws change). Any changes will be immediately posted on Our Site and you will
be deemed to have accepted the terms of the Privacy Policy by continuing to use our
Services and on your first use of Our Site following the alterations. We recommend that
you check this page regularly to keep up-to-date since the latest version published on
Our Site will supersede any previous versions