Data Protection Policy

Introduction

As a domestic staff recruitment company, SortYourHelp (“SYH”) is obliged to comply with data protection legislation in the UK, and in particular the EU General Data Protection Regulation (“GDPR”) which has been brought into the UK via the Data Protection Act 2018.

This Data Protection Policy (“DPP”) sets out details of SYH’s commitment to protecting your data whether you are a client (“Client”), a candidate, (“Candidate”) a supplier or another third party, and how that commitment is implemented in respect of the collecting, processing, using, storing and sharing of personal data and how we keep that information safe and confidential.

“Personal Data” is any information identifying a living, identifiable individual, excluding any anonymous data but including any sensitive Personal Data. Such data can be factual such as a name, email address, date of birth or national insurance number; or an opinion or reference about a person’s actions or behaviour.

“Processing” means any activity involving the use of Personal Data whether that is obtaining, holding, recording or carrying out any operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. It includes the transmission or transferring Personal Data to third parties.

Cath Kenny, a director of SYH, is the data controller and is responsible for your Personal Data, including determining when, why and how to Process Personal Data. For any Data Protection queries please email dataprotection@sortyourhelp.com

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at dataprotection@sortyourhelp.com.

Background

This DPP has been written in accordance with the principles and safeguards set out in the GDPR. We adhere to the principles relating to the Processing of Personal Data set out in GDPR which require Personal Data to be:

1. Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
2. Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
4. Accurate and where necessary kept up to date (Accuracy).
5. Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
7. Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
8. Made available to individuals such as to allow them to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

Purposes for Processing your Personal Data

Set out below is a description of the ways we intend to use your Personal Data and the legal grounds on which we will Process such data. We have also explained what our legitimate interests are, where relevant.

Purpose/Activity	Type of data	Lawful basis for Processing
To register you as a new Client	Identity Contact Details concerning your family	To find a suitable Candidate for you in accordance with our Terms and Conditions.
To register you as a new Candidate	Identity Contact Job experience Skills and qualifications	To use all reasonable endeavours to find you suitable employment / engagement.
To manage our relationship with you, including notifying you about changes to our Terms and Conditions or privacy policy.	Identity Contact Profile Marketing and Communications	Necessary for our legitimate interests to keep our records updated and to study how our Clients use our services.
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests for running our business; Provision of administration and IT services, network security and to prevent fraud.
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests to develop our services and grow our business.

Information we obtain from other sources

In addition, we may obtain information about our Candidates from other sources such as job board websites, our SYH Nanny Network on Facebook and Whatsapp (Candidates can join and remove themselves at any time from both), online CV libraries, references, personal recommendations, and referees. Such information shall be held by us for the purpose of complying with our obligations to our Clients and Candidates.

Information on new roles and/or services

You will receive communications from us if you have:

1. requested information from us or registered with us as a Candidate or Client; or/li>
2. if you are a Candidate and have provided us with your details and have consented to us sending you communications relating to job opportunities and/or other services; and
3. in each case, you have not opted out of receiving that information.

We will never share your Personal Data with any third party for marketing purposes.

Disclosures of your personal data

We may have to share your Personal Data with Clients who are looking for suitable Candidates to fulfil a role that they are offering.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of Processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your Personal Data and to treat it in accordance with the law. We only allow such third parties to Process your Personal Data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your Personal Data outside the EU, except to countries which are compliant with equivalent or EU regulations.

Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only Process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your Personal Data 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 you can ask us to delete your data and it is our responsibility to make sure that any Personal Data we retain is accurate. So, if you would like us to erase your data (to the extent that we are able) or there are any changes to your data which means what we currently hold is inaccurate, please do let us know.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These include the right to:

Request access to your Personal Data. Request correction of your Personal Data. Request erasure of your Personal Data. Object to Processing of your Personal Data.

Request restriction of Processing your Personal Data.

• Request transfer of your Personal Data.
• Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at dataprotection@sortyourhelp.com.

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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.