At Impact Retail Ltd (‘the Company’; ‘Impact Retail’; ‘Impact’) we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Notice describes the personal information that Impact Creative collects from or about you, how we use it, and to whom we disclose it.
This Notice is written to comply with our duties under the General Data Protection Regulation 2018.
2. What is personal information?
Personal information is information which relates to a living individual who can be identified from the information (or from that information and any other information in the possession the Company). This includes both factual information and opinion as expressed by a third party. Excepted from this definition is any information that is derived from your job title or business contact information. Your work email address, and your work emails, for example, do not constitute personal information.
Personal information includes information such as name, home address, telephone, personal email address, date of birth and marital status, and any other information which we may ask you to disclose for operational reasons in the course of your application for and employment with us. Examples of where personal information is found in the context of recruitment and employment include:
- CVs and application forms
- References and interview notes
- Photographs and video
- Offer letters and Contracts
- Payroll information (including NI number, bank details)
- Forms connected to employee benefits
- beneficiary and emergency contact information
Personal information does not include anonymous or non-personal information.
3. Why do we process personal information?
There are a number of reasons why we process personal information in the course of your employment (and/or your application for employment). As a candidate and as a new employee you need to be properly identified to us; effectively, we need to know that you are who you say you are and that you are eligible to work with us.
We process personal information so that you can be paid and receive benefits. Through the course of your employment your personal information must be retained so that we have an accurate record relating not only to your pay but also to your performance. We may need to have information about your health (particularly so that we can support your wellbeing) and we must have your emergency contact information. Should you leave us, we must necessarily hold on to some of your personal information as we may be required to share this with HMRC or other official bodies.
4. Where do we collect the information from, and where do we pass it to?
As a general rule, Impact Retail collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (for example, an employment reference).
Where we work with third parties with whom we share personal information– agencies, Ink HR – we will take steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us and that they can vouch for the measures they have in place to protect it.
The work output of Impact Retail’s employees, whether in paper record, computer files, or in any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by Impact Retail.
In the course of conducting our business, we may monitor employee activities and our premises and property. We may also monitor all employees' computer and e-mail use. This does not mean that all employees will be monitored or that their actions will be subject to constant surveillance. However, such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources). When using Impact Retail equipment or resources employees should not have any expectation of privacy with respect to their use of such equipment or resources.
6. In what circumstances do we disclose your personal information?
We may disclose your personal information in the course of establishing, managing or terminating your employment relationship with us. This includes sharing information with parties that provide products or services to us or on our behalf and with parties that collaborate with us in the provision of products or services to you. Examples of this include:
- to comply with legal or regulatory requirements. We will try to not disclose more personal information than is required for the circumstances;
- to comply with valid legal processes such as search warrants, subpoenas or court orders; to protect the rights and property of Impact Creative; or
- to protect the safety of a person or group of persons during emergency situations or where necessary.
For any other purpose we will obtain your consent to disclose your personal information.
7. Notification and consent
Privacy laws do not require Impact Retail to obtain your consent for the collection, use, or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so. Examples of this may be pension or payroll reporting and compliance.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to Impact Retail collecting, using and disclosing your personal information for the purposes stated in this Privacy Notice. If you wish to formally withdraw such consent you must make a formal written request to do so to the Managing Director.
8. How is your personal information protected?
We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure. As part of our safeguarding, we require you to comply with the security protocols we have in place at any time in relation to our physical and IT environment. Please see our associated Telecoms, IT, Internet & Email Policy and our Data Protection Policy.
9. How long is your personal information retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, Impact Retail endeavors to retain your personal information only for as long as it believes is necessary to fulfil the purposes for which the personal information was collected (including for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you. In most cases your data will be entirely deleted 6 years after you have left the Company.
10. Updating your personal information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, it is your responsibility to keep us informed of such changes and to maintain your own online HR file accordingly.
11. Access to your personal information
You have access to your personal information through our online HR system. If you believe that we hold additional personal information that you would like to review, verify or correct please contact Ink HR in the first instance. Please note that any such communication must be in writing.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question. An example of this might be where you disagree with the outputs of a performance review.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices.
If we cannot provide you with access to your personal information, we will try to inform you of the reasons why, subject to any legal or regulatory restrictions.