FAIR PROCESSING NOTICE
IN-SYNC Digital Ltd (ISD) takes the protection and privacy of personal data seriously. This Fair Processing Notice explains how we will use our Operative’s personal data before, during and after being an Operative working on a project through IN-SYNC Digital Ltd.
Our contact details
4 The Millennium Centre,
Surrey, GU9 7XX
Telephone number: 01252 705 288
Our Data Protection Officer can be emailed at [email protected]
What personal data do we collect about you, how do we use that personal data, and what is our legal basis?
We need a legal basis in order to process your personal data. Any data we process is because we either have a contract with you (or you wish to obtain a contract with us), we have a legal obligation to do so, or because it is a legitimate activity. On occasion, we will seek your consent to process your personal data, but you are free to refuse.
When you are an operative or wish to become an operative of IN-SYNC Digital Ltd, we collect and process your personal data:
• in order to fulfil our contract for services with you;
• to fulfil our legal obligations under Right to Work legislation;
• where the activity is a legitimate one for a business; and
• with your consent for marketing.
We process your personal data because we have a contract with you, you would like to enter into a contract with us or it is a legitimate business activity.
We process the following data to provide you with services and to contact you. Our legal basis to do so is because we have a contract with you or you would like to enter into a contract with us. We cannot provide you with a contract without this information.
• your name
• date of birth
• NI number
• home phone
• email address
• your financial data
• your employment data
• Unique Tax Reference number (UTR, verification for tax and CIS)
Once you become an Operative with IN-SYNC Digital Ltd, we will assign you a unique identifier number as this is a legitimate activity in order to avoid any system errors or mistakes in making payments.
We will send you relevant information on auto-enrolment pensions (if appropriate) and HMRC update as part of our contractual service with you.
If you have a beneficiary or next of kin, we will collect and process their name, address, phone and DOB as this is a legitimate activity for us. Next of kin will only be contacted in emergency circumstances if it is in your vital interest that we do so.
We process your personal data because we have a legal obligation to do so.
Right to Work in the UK
In order to comply with our legal obligations under Right to Work legislation, we need to confirm your identity and will process any of the following documents to do so. We cannot have a contract with you unless we can verify your identity and right to work in the UK.
- A passport showing the holder, or a person named in the passport as the child of the holder, is a British citizen or a citizen of the UK and Colonies having the right of abode in the UK.
- A passport or national identity card showing the holder, or a person named in the passport as the child of the holder, is a national of a European Economic Area country or Switzerland.
- A Registration Certificate or Document Certifying Permanent Residence issued by the Home Office to a national of a European Economic Area country or Switzerland.
- A Permanent Residence Card issued by the Home Office to the family member of a national a European Economic Area country or Switzerland.
- A current Biometric Immigration Document (Biometric Residence Permit) issued by the Home Office to the holder indicating that the person named is allowed to stay indefinitely in the UK, or has no time limit on their stay in the UK.
- A current passport endorsed to show that the holder is exempt from immigration control, is allowed to stay indefinitely in the UK, has the right of abode in the UK, or has no time limit on their stay in the UK.
- A current Immigration Status Document issued by the Home Office to the holder with an endorsement indicating that the named person is allowed to stay indefinitely in the UK or has no time limit on their stay in the UK
- National Insurance number and their name issued by a Government agency or a previous employer.
- A full birth or adoption certificate issued in the UK which includes the name(s) of at least one of the holder’s parents or adoptive parents,
- A birth or adoption certificate issued in the Channel Islands, the Isle of Man or Ireland
- A certificate of registration or naturalisation as a British citizen
- A current Residence Card (including an Accession Residence Card or a Derivative Residence Card) issued by the Home Office to a non-European Economic Area national who is a family member of a national of a European Economic Area country or Switzerland or who has a derivative right of residence.
- A current Immigration Status Document containing a photograph issued by the Home Office to the holder with a valid endorsement indicating that the named person may stay in the UK, and is allowed to do the type of work in question
- A Certificate of Application issued by the Home Office under regulation 17(3) or 18A (2) of the Immigration (European Economic Area) Regulations 2006, to a family member of a national of a European Economic Area country or Switzerland stating that the holder is permitted to take employment which is less than 6 months
- An Application Registration Card issued by the Home Office stating that the holder is permitted to take the employment in question
- A Positive Verification Notice issued by the Home Office Employer Checking Service to the employer or prospective employer, which indicates that the named person may stay in the UK and is permitted to do the work in question.
- In order to process the identity checks, we will use credit reference agencies (“CRAs”). These checks are regulatory requirements.
To do this, we will supply your personal information to CRAs and they will give us information about you. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
Verify the accuracy of the data you have provided to us; and
Prevent criminal activity and fraud.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. IN-SYNC Digital Ltd uses Callcredit as our CRA. Callcredit’s role is also as a fraud prevention agency, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with Callcredit are explained in more detail at www.callcredit.co.uk/crain
We process your personal data with your consent and where it is a legitimate business activity.
We will send you information pertaining to IN-SYNC Digital Ltd because you are an Operative of ours as this is a legitimate business activity. We will also send you this information for one year after you have left IN-SYNC Digital Ltd as you may wish to come back to us and this is a legitimate activity.
You have the right to unsubscribe to marketing at any time. If you do choose to unsubscribe, we will keep your name and email address on a suppression list so that we don’t email you again by accident and this is a legitimate activity for us.
We will ask for feedback on our products or services in order to monitor and improve our service delivery, and this is a legitimate activity for us. You can complete these questionnaires if you wish to, however you are not obliged to do so. These questionnaires are not anonymous.
If you are on our suppression list, you will still receive communications that are necessary to the performance of your chosen services, or notifications to avoid you missing deadlines and/or incurring penalties.
How long do we hold your personal data?
We will hold your personal data that was collected for right to work purposes for two years from when you ceased a relationship with IN-SYNC Digital Ltd, after which it will be destroyed. This is a legal obligation.
We will hold the personal data that was collected for the purposes of engaging you for seven years, after which it will be destroyed. This is a legal obligation.
We will hold your name, email and phone number to send you marketing information as long as you would like us to do so. If you withdraw your consent, we will hold this data for five years in a suppression list so that we don’t market to you against your wishes.
If you have started the process to become an Operative and then changed your mind or it you are not accepted as an Operative, we will hold your data for two years, after which it will be destroyed. We hold it for two years in case it is required for by law enforcement agencies, the Home Office or for legal reasons.
Do we use any automated decision making?
We do not use any automated decision making.
- Who do we share your personal data with?
- Depending on your personal circumstances we may share your personal data with the following recipients:
- HMRC for the purpose of providing your chosen services and responding to requests for information;
- Home Office for the purpose of any right to work checks or queries;
- Our software, technology applications, database providers (Merit Software Ltd, Campaign Monitor Pty Ltd, DocuSign UK Ltd, Microsoft, SmartSheet Inc, TextAnywhere Ltd, Text Marketer Ltd, Signable Ltd,) necessary for recording, securing and updating your personal details and administering services internally as well as external communications;
- Callcredit Information Group Ltd for the purpose of identification, address and bank account verification;
- Barclays Bank Plc for the purpose of making payments;
- Capita Pay360 for the purpose of administering payments;
companies that verify publicly available documents and information (e.g. Credit Reference Agencies, Home Office);
- High Court Enforcement Officers Association for the purposes of enforcing High Court writs to seize and sell assets to settle unpaid judgements;
- Information Commissioners Office in the event of a request for information or breach;
- IN-SYNC Group Companies (only with your consent) for marketing relevant services.
- Legal advisors and consultants
- Insurance companies
Do we transfer your personal data outside of the EU or EEA?
Your data is kept in the EU or EEA except for data that is processed by SmartSheet Inc, a technology application used by us to create administrative spreadsheets.
SmartSheet Inc is located in the USA, which is non-adequate country for data transfer as determined by the European Commission. Your data is protected by SmartSheet Inc as they participate in and have certified their compliance with the EU-U.S. and US-Swiss Privacy Shield Frameworks and Principles (collectively, the “Privacy Shield Principles”). Smartsheet will comply with the Privacy Shield Principles with respect to the personal data that it receives in the United States from the European Economic Area and Switzerland. You can review the Privacy Shield Principles, learn more about Privacy Shield, and view SmartSheet Inc’s Privacy Shield certification at https://www.privacyshield.gov/. Smartsheet’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
- You have rights in respect of our processing of your personal data which are:
To access to your personal data and information about our processing of it. You also have the right to request a copy of your personal data (but we will need to remove information about other people).
To rectify incorrect personal data that we are processing.
To request that we erase your personal data if:
- we no longer need it;
- if we are processing your personal data by consent and you withdraw that consent;
- if we no longer have a legitimate ground to process your personal data; or
- we are processing your personal data unlawfully
- To object to our processing if it is by legitimate interest.
- To restrict our processing if it was by legitimate interest.
- To request that your personal data be transferred from us to another company if we were processing your data under a contract or with your consent and the processing is carried out automated means.
If you want to exercise any of these rights, please contact us on 01252 705 288 or email our Data Protection Officer on [email protected]
You also have the right to lodge a complaint about our processing with the UK's Information Commissioner's Office.