Edwin People Privacy Policy

Date last revised: February 2024

Privacy Policy

EDWIN PEOPLE LIMITED (we/us/our) process personal data in connection with providing our HR consultancy services to our clients only. We are committed to protecting all personal data we process in connection with performing our business. We process personal data in accordance with this privacy policy, applicable data protection laws, the Information Commissioner’s Office (ICO) guidance or best practice, and in accordance with the requirements of our contracts agreed with our clients. 1. THIS POLICY 1.1 This policy sets out how we process personal data. As we do not employ data subjects, we do not capture personal data from data subjects directly, so this policy is published on our website at edwinpeople.com but is not directly accepted by individuals – it is for information and reference only. We process personal data as a data processor on behalf of our clients (MATs or schools), who are either data controllers or data processors. 1.2 This policy is not intended to be a contractual document unless expressly stated in any relevant contract we enter into. 1.3 Terms used within this policy shall have the meaning(s) given in the Data Protection Act 2018 (Act), the EU General Data Protection Regulation (2016/679) (GDPR) and/or the UK GDPR, as applicable. 1.4 Any changes or updates we make to this policy will be posted on this page. Any changes will apply when you continue to work with us after the date of the relevant change, so you may need to update policyholders directly. 1.5 If you have any queries relating to this policy, please contact us at dpo@edwinpeople.com. 2. WHO WE ARE 2.1 For the purposes of the Act, the data controller will be our client. Edwin People Limited (number 15343583) is a data processor only and our registered office is at 1st Floor (South), Cathedral Buildings, Dean Street, Newcastle NE1 1PG. 2.2 We are registered with the ICO to process personal data and our registration number is ZB648163 2.3 All personal data that we process is held and stored by us in our internal management systems on servers located either within the UK or the wider EEA (either Germany or Ireland). All of our staff who process, or are likely to process, personal data in connection with our HR services function are UK based. 3. BASIS FOR PROCESSING 3.1 We do not process personal data on the basis of consent. Personal data is processed by us to perform our contract with our client. 3.2 All personal data we process is reasonable and necessary to enable us to perform the above summarised services. 3.3 We do not contract with data subjects directly. By working with us, you must notify data subjects with whom you process their personal data that you use our services, you transfer their personal data to us and that we will process their personal data. 3.4 We host all personal data relating to contacts we liaise with in connection with our services through our wider group databases, and access to that data is made available to other companies within the Edwin Group and may be used for marketing and data analytics purposes. 3.5 Data within any documents or reports that we receive in connection with our services is not accessed by third party group companies or used for marketing or data analytics purposes at any time. 4. DATA WE PROCESS 4.1 We process personal data contained in reports provided to us in Word, Excel or PDF by our clients directly from their systems. These reports contain contact information (including names, addresses, emails, telephone numbers), NI numbers, previous experience, financial information (including salary, tax and bank account details), information relating to work absences and special category data ordinarily processed by our client as the employer of data subjects. We do not capture or receive any personal data from third parties relating to data subjects. 4.2 We process personal data relating to employment tribunal claims or related insurance policy complaints or claims, where necessary. 4.3 We also collect personal data from website users through cookies and Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses "cookies", which are text files placed on your computer to help analyse how you use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the USA. Google will use this information for the purpose of evaluating your use of our website, compiling reports on your activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this your ability to use our website may be restricted. By using the website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. 4.4 We automatically collect technical information about the device you use to visit our website, including your IP address, browser type / version and related settings. We also use cookies to monitor website use and how you interact with it. 5. HOW WE USE IT 5.1 We use personal data contained in reports provided to us to provide HR and leadership advisory functions to our MAT and school clients. 5.2 In all cases, the personal data we process is returned to our client who disclosed it to us. We do not pass the contents of any reports to third parties unless agreed with our client. 5.3 We do not use third parties to process any personal data on our behalf in connection with our services, our software, web portal or our contracts. Only our Cloud-hosting services provider is engaged to process our personal data at any time and they are based in the UK, Germany and Ireland. 6. DATA SUBJECTS’ RIGHTS 6.1 Data subjects can contact us directly at any time to ask us to clarify what personal data (if any) we hold about them, how it was obtained and why we use it. Where we do process any of their personal data, they can ask us to amend any inaccurate data, delete data they think we no longer need, or to reduce the circumstances in which we process it. 6.2 We can provide support to our client in connection with any rights exercised by data subjects at any time. Any support we do provide is as agreed with our client in our client agreement or other relevant contract. 6.3 We have the capacity to extract personal data from our databases, but as we do not capture personal data from data subjects directly, any data we process duplicates personal data processed by our clients contained in the relevant reports we receive from them, and you (as data subject) will need to also ask them to delete your personal data (if required). We cannot ask our client to do that on your behalf. 6.4 If you wish to exercise your rights at any time, please contact us on the details set out at the beginning of this policy. We will require you to verify your identity to us before we can provide any personal data to you, and we reserve the right to ask you to specify the types of personal data you want to see. We may also notify our client, if you have not already done so.