Introduction
Contex is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect, use and store personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) which came in to effect 25th May 2018. This document applies to all employees, workers and contractors.
General
Contex is a “data controller”. This means that we are responsible for deciding what personal information we hold and how we use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former employees, workers and contractors.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
How we will use information about you
We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
• Where we need to perform the contract we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.
What types of personal information do we handle?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are also “special categories” of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers, personal email addresses and date of birth.
• Location of employment or workplace.
• Employment records (including job titles, work history, working hours, training records and professional memberships).
• Photographs for various business purposes – website, company presentations etc.
We may also collect, store and use the following “special categories” of more sensitive personal information.
How we collect personal information
We use different methods to collect data from and about you including through:
• Direct interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with the contex website. This includes personal data you provide when you: sign in for services; create an account on our website; make a support enquiry.
• Automated technologies or interactions
As you interact with our website and service, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
When will we use your personal information
We need all the categories of information in the list above (under “What types of personal information do we handle”) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations.
The situations in which we will process your personal information are listed below:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
How we use particularly sensitive information
”Special categories” of particularly sensitive personal information require higher levels of protection. We may use this information for regular reporting such as equality and diversity monitoring and management information.
We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations and in line with our data protection policy.
• Where it is needed in the public interest, such as for equal opportunities monitoring and in line with our data protection policy.
• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
Failure 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, or we may be prevented from complying with our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data Sharing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
Data Security
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 appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
Data Retention
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.
Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
You have certain rights in relation to the personal information we hold about you. In particular you have the right to:
• Request a copy of personal information we hold about you;
• Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
• Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
• Object to our processing of your personal information; and/or,
• Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
If you would like to exercise these rights or understand if these rights apply to you, please contact us in writing – management@cmr.london or
231-232 Strand, London WC2R 1DA
Changes to this 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.
If you have any questions about this privacy notice, please send an email to management@cmr.london
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.