Culture Shift Privacy Notice
Cultureshift Communications Ltd: GDPR Privacy Notice and Consent Form
This privacy notice and consent form applies to all Cultureshift Communications Ltd (“Culture Shift”) Employees. Culture Shift takes seriously the privacy and security of your personal information.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
Culture Shift is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this notice, so that when we are collecting or processing personal information about you, you are aware of how and why we are using such information.
Below is our Privacy notice which explains how we use any personal information we collect about you.
Privacy Notice
This privacy notice also explains other important information about Culture Shift managing your personal data.
Why do we need to collect and use your personal data? We collect and use personal information about you:
- to allow us to perform our contract with you
- to enable us to comply with legal obligations.
- to pursue legitimate interests of our own
We have set out below more detail about the situations in which we will process your personal information.
- Deciding about your recruitment or appointment.
- Deciding upon the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Paying you and, if you are an employee, deducting tax and National Insurance contributions.
- Providing employment benefits to you, including liaising with providers
- Business management and planning, including accounting and auditing.
- Carrying out performance reviews, and managing your performance
- Setting and reviewing pay and benefits.
- Reviewing your performance, including decisions about promotions.
- Dealing with disciplinary hearings.
- Dealing with complaints raised by you including grievances.
- Making arrangements for the termination of our working relationship.
- Considering your fitness to work.
- Managing sickness absence.
- Complying with health and safety obligations.
- To prevent fraud.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies to review and better understand employee retention and attrition rates.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Failing to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Do we need your consent?
We do not need your consent if we use your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our regulatory obligations and provided we do so in line with our recruitment and data protection policy.
We may also use information relating to criminal convictions where it is necessary in relation to legal claims.
Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
Who might we share your information with?
We may have to share your data with third parties, including third-party service providers and other entities in the group. The following activities are typically carried out by third party service providers pension administration, payroll, benefits provision and administration, IT services.
We require third parties to respect the security of your data and to treat it in accordance with the law.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How secure is my personal information?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long do we keep hold of your information?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
We are also subject to regulatory requirements to retain your data for specified minimum periods.
These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 5 years after any relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Your rights in connection with personal information we hold about you? Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer.
If you wish to make a data subject access request or find out more about this process, please contact the Data Protection Officer.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer, once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Please be aware that there are likely to be implications on our ability to continue our working relationship in the event that we are not able to process your personal information.
Changes to the privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Who should I contact
If you have any questions, concerns or comments regarding our data processing practices, you can contact our data protection officer.
Further information on data protection (including your right to complain about the use of your personal data) can be found on The Information Commissioner's Office (ICO), website www.ico.org.uk