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Privacy (Data Protection) Policy

Policy

1.1       This policy provides the direction and guidance for managing personal information within Heartfelt HR Ltd (the Company).

1.2       This Policy may be subject to change from time to time, at the company’s discretion.

1.3       A company that processes personal data must name an individual who is responsible for correct gathering, processing, control and deletion of such data: the Data Controller.  Our Data Controller is Jill Aburrow, Company Director.

 Principles

2.1       Personal Data is any information that can be used to identify a particular individual either directly or indirectly.  This includes such identifying information as name; an identification number; location data; an online identifier; or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

2.2       The rights of the individual, in respect to their personal data include the following rights:

• to be informed of how their personal data is going to be processed and stored;
• to gain unimpeded access to their own personal data;
• to have their personal data corrected;
• to have their personal data erased (the right to be forgotten);
• to restrict the processing of their personal data;
• to view their personal data in common electronic format;
• to object to the processing of their personal data;
• to ask that we transfer the personal information they gave us to another organisation, or to them, in certain circumstances.

2.3       You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

2.4       Please contact us at jill@heartfelthr.com if you wish to make a request.

2.5       The Company is required to obtain positive consent from individuals prior to storing and processing their data.

Collecting Personal data

3.1       We currently collect and process the following information for transactions through our website:

• Personal name and email address;
• Other personal contact details;
• Personal bank or building society details;

3.2       If you are, or become, a current or previous client, we currently collect and process the following to enable the client/provider relationship

• Personal name, job title, company email address and contact telephone number of any authorised client contacts
• Personal name, job title, company contact details of any employees where we are advising on a particular HR issue with regard to that employee. This may also include details of salary and remuneration.  If we need an employee’s personal contact details (for example to arrange outplacement support in a redundancy situation), we will gain permission from the individual employee.

3.3       Most of the personal information we process is provided to us directly by you for one of the following reasons:

• For our marketing purposes (our mailing list);
• To provide our products and/or services to you effectively;
• To collect your payment for our products and services or to make refund of such;

3.4       We use the information that you have given us in order to provide our products and services to you and to collect payment for those products/services.  We also use the information that you have given us to keep you updated on new products and services which may be of interest to you.

3.5       If you are employed by one of our current or previous client companies, we may need to access your personal details such as your name, contact details (work), salary information and other personal information to enable us to advise the client appropriately.  Any personal information collected in this way will be treated as other personal information outlined in this policy. 

3.6       We may share this information with:

• A third party legitimately providing services to our business (such as a mailing list facilitation service; IT support, Accountancy and Bookkeeping services; Virtual Assistant, etc). Such third party will be required to hold a similar Privacy Policy.
• law enforcement agencies, as required for official reasons;

Processing Personal Data

4.1       The Company will process personal data as long as it has a legal basis to do so.  We will only keep personal data as follows:

• once the individual has freely given consent for its use;
• for the duration for which it was requested;
• in a documented and secured location to prevent duplication and error.

4.2       The Company will document the processing of any personal information as follows:

• the legal basis for its use;
• the agreement of the individual;
• the location of the data;
• who it has been sent to (third party outside the Company);
• when the data was updated, with a reason for the update;
• when it was deleted (if requested, or no longer required);
• details of its retention once processing has been completed.

4.3       We ensure that personal data is obtained and stored in designated areas and documented accordingly.  

4.4       The individual data subject has the right to remove or amend data held on them at any time.  We will  fulfil any request to amend or delete information and will record the activity accordingly.

Storing personal data

5.1       As part of our business processes and information flows, we hold personal data in the following areas:  secured computer and technology storage.  Paper records are not retained.

5.2       Personal data is only located in the locations specified and is appropriately protected. 

Personal Data Retention

6.1       Personal data will be kept as long as there is a legal basis for retention. 

6.2       In order to ensure the Company complies with all of its regulatory and legislative obligations, it will employ the following retention policies:

• Information which cannot on its own be used to identify a particular person (ie. “pseudonymised” data) will be retained for accountability purposes;
• Data relating to financial transactions will be kept for seven years;
• Information about employees of our clients will be held for up to six years.

Cookies

7.1       A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

7.2       This website (heartfelthr.com) may use cookies for the following services:

• To remember items in a shopping basket
• To provide essential security measures
• For quick loading and distribution of content
• To analyse visitors to the website and social media pages
• To remember your user preferences
• For our own and third party advertising
• For social media buttons (eg. “likes” on Facebook)

7.3       You are warned about the use of cookies on the website when you first visit the site so that you have the choice whether or not you wish to continue using the website.

Controlling your personal information

8.1       If you have previously agreed to us holding your personal information or using it for direct marketing purposes, you may change your mind at any time by emailing us at jill@heartfelthr.com

8.,2      We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

8.3       You may request details of personal information which we hold about you. If you would like a copy of the information held on you please email us at jill@heartfelthr.com

8.4       If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible at jill@heartfelthr.com.  We will promptly correct any information found to be incorrect.

How to complain

9.1       If you have any concerns about our use of your personal information, you can make a complaint to us at jill@heartfelthr.com.

9.2       You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s   contact information is:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Heartfelt HR Ltd

May 2023

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