Praetura Assist Finance privacy notice - Report + Support - Praetura Ventures

Praetura Assist Finance privacy notice

PRAETURA ASSET FINANCE LTD PRIVACY NOTICE FOR WORKERS, CONTRACTORS AND EMPLOYEES

We are committed to respecting your privacy. This notice is to explain how we will use personal information we
collect before, during and after your working relationship with us.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services.

This privacy notice does not apply to you if you are a client (our engagement letter and terms of business state the nature and purposes of our processing).

References to we, our or us in this privacy notice are to PRAETURA ASSET FINANCE LIMITED, a company
incorporated and registered in England and Wales (company number 08426091), whose registered office is at
Ewood House, Walker Park, Walker Road, Blackburn, BB1 2QE.

1 PERSONAL INFORMATION

When you interact with us in relation to your work with us, you will provide us with or we will obtain personal
information about you, such as information regarding your:
personal contact details such as name, title, addresses, telephone numbers and personal email addresses;
date of birth;
gender;
marital status and dependants;
next of kin, details of family members and emergency contacts;
national insurance number and other tax or governmental identifiers;
bank accounts, payroll and tax status;
salary, annual leave, pension and benefits;
start date and leaving date;
location of employment or workplace;
driving licence (including copies where we are required to hold such information for identification or insurance purposes where you are to use our vehicles);
recruitment (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process);
employment records (including job titles, work history, working hours, training records and professional memberships);
compensation history;
pension and pension entitlements;
performance including that generated through our appraisal systems;

disciplinary and grievance information;

movements though CCTV footage and other information obtained through electronic means such as swipecard and key fob records;
use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use;
image in photographic form;
shareholding, option, and dividend entitlement; and
loans that you have made to us.

Where we have specifically notified you and you have given your consent we will also collect, store and use the following “special categories” of more sensitive personal information regarding you:
information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
information about your health, including any medical condition, health and sickness records; and
information about criminal convictions and offences.

Depending on the nature of our interactions with you, there will be certain essential personal information that
we must collect from you in relation to your relationship with us. This will vary depending on the relationship
we have with you.

We will also ask you for additional personal information where relevant which it is optional for you to provide
but which will allow us to better tailor our relationship with you. For example, you may provide us with
additional contact details to make it easier for us to get in touch with you, or with additional information
about your dietary preferences in connection with a social engagement.

We will always aim to make it clear which personal information it is necessary for you to provide and which
personal information is optional. However, if you are unsure as to whether you are required to provide any
particular piece of personal information please ask.

We typically collect personal information about employees, workers and contactors through the application
and recruitment process, either directly from candidates or sometimes from an employment agency or
background check provider. We will sometimes collect additional information from third parties including
former employers, credit reference agencies or other background check agencies. We will also collect
additional personal information in the course of job-related activities throughout the period of you working
for us.

2 USES MADE OF THE INFORMATION

We are committed to protecting your privacy, and will only use your personal information in accordance with
applicable data protection legislation, including the General Data Protection Regulation and the UK
implementing legislation. 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; and
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 will 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); and;
where it is needed in the public interest.

We need all the categories of information in the list in paragraph 1 above primarily to allow us to perform our
contract with you [◊] and to enable us to comply with legal obligations [◊]. In some cases we will use your
personal information to pursue legitimate interests of our own or those of third parties [◊], provided your
interests and fundamental rights do not override those interests. As we have indicated there are more limited
circumstances where we process personal data pursuant to your consent [◊]. The situations in which we will
process your personal information are listed below. We have indicated by colour coding the purpose or
purposes for which we are processing or will process your personal information:
making a decision about your recruitment or appointment; ◊
determining the terms on which you work for us; ◊
checking you are legally entitled to work in the UK; ◊
ensuring that we maintain proper business records; ◊ ◊ ◊
paying you and, if you are an employee, deducting tax and National Insurance contributions; ◊
providing benefits of employment, including flexible benefits; ◊
liaising with your pension provider; ◊
administering the contract we have entered into with you; ◊ ◊
business management and planning, including accounting and auditing; ◊ ◊
conducting performance reviews, managing performance and determining performance requirements; ◊
making decisions about salary reviews and compensation; ◊
assessing qualifications for a particular job or task, including decisions about promotions; ◊ ◊
gathering evidence for possible grievance or disciplinary hearings; ◊
making decisions about your continued employment or engagement; ◊
making arrangements for the termination of our working relationship; ◊
education, training and development requirements; ◊
dealing with legal disputes involving you, or other employees, workers and contractors, including
accidents at work; ◊
for the purposes of ensuring the security of our systems and information as well as client information;
◊ ◊ ◊
ascertaining your fitness to work; ◊ ◊
managing sickness absence; ◊
complying with health and safety obligations; ◊ ◊ ◊
to prevent and detect criminal or improper acts; ◊ ◊ ◊
to monitor your use of our information and communication systems to ensure compliance with our IT policies; ◊ ◊
to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; ◊ ◊
to conduct data analytics studies to review and better understand employee retention and attrition rates; ◊
for the purposes of equal opportunities monitoring; and ◊ ◊
for the purposes of managing your shareholding in us, your rights to shares and dividend details. ◊ ◊

Some of the above grounds for processing will overlap and there may be several grounds which justify our
use of your 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 (such as paying you or providing a benefit), or we may be prevented from
complying with our legal obligations (such as to ensure the health and safety of our workers).
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 will process your personal information without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.
We will also use information regarding your usage of the computer systems and facilities we make available
to you, including your internet browsing history, the emails you send and receive and any removable media
that is inserted into one of our computers. Such information is used for the basis of accounts and records, to
determine that any personal usage of these systems is reasonable, in relation to determining your transactions or interactions with other personnel, clients and suppliers and in relation to the security of these
systems. We have a legitimate interest in so doing.

Where relevant depending on the role you carry out for us we will monitor telephone calls that you make in
accordance with our separate policy and the regulatory requirements (we are entitled to review and
retain all logs of telephone calls). We will not review the content of any e-mail that you send or receive that
has the text “Private:” in the subject line unless we have evidence of improper conduct and reasonably
consider that these e-mails may be related to the improper conduct.
”Special categories” of particularly sensitive personal information require differing levels of protection. We
need to have further justification for collecting, storing and using this type of personal information. We will
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 or perform a contract with you;
where it is needed in the public interest, such as for equal opportunities monitoring; and
where it is needed to assess your working capacity on health grounds, subject to appropriate
confidentiality safeguards.
Less commonly, we will 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 will use your personal information in the following special categories in the following ways:
we will use information relating to your absence from work, which will include sickness absence or
family-related absences, to comply with employment and other laws;
we will use information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work;
we will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace
adjustments, to monitor and manage sickness absence and to administer benefits; and
we will information about your protected characteristics in accordance with the Equality legislation from time to time, to ensure meaningful equal opportunity monitoring and reporting.

We do not need your consent if we use special categories of your personal information in accordance with
our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.

In limited circumstances, we will approach you for your written consent to allow us to process certain
particularly sensitive data. If we do so, we will provide you with full details of the information that we would
like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be
aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Where you have given us your consent to use your personal information in a particular manner, you have the
right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 8.
Please note however that the withdrawal of your consent will not affect any use of the data made before
you withdrew your consent and we will still be entitled to hold and process the relevant personal information
to the extent that we are entitled to do so on bases other than your consent.
You will not be subject to decisions that will have a significant impact on you based solely on automated
decision-making, unless we have a lawful basis for doing so and we have notified you.

3 DISCLOSURE OF YOUR PERSONAL INFORMATION

We will share your personal information only where it is necessary to administer the working relationship or
we have a legitimate interest in so doing. We will also disclose your personal information to third parties if
we are under a duty to disclose or share your personal information in order to comply with any legal
obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect rights,
property, or safety of our other employees, workers and contractors our customers, ourselves or others. with
you or where we have a legitimate interest in doing so. This includes exchanging information with other
companies and organisations for the purposes of providing references and fraud protection.

”Third parties” includes third-party service providers (including contractors and designated agents).
The third parties we share your personal information with where required by law are courts and governmental
agencies.
The third parties we share your personal information with where it is necessary to administer the working
relationship with you include (where you are a contractor) any client of ours for whom you are ultimately

providing services to.

The following activities are carried out by third-party service providers: payroll, pension administration,

benefits provision and administration and IT services. All our third-party service providers are required to
take appropriate security measures to protect your personal information in line with our policies. We do not
allow our third-party service providers to use your personal data for their own purposes. We only permit them
to process your personal data for specified purposes and in accordance with our instructions.

We will share your personal information as part of our regular reporting activities on company performance,
in the context of a business reorganisation or restructuring exercise, for system maintenance support and
hosting of data. All our employees are bound by this privacy policy.
We will share your personal information where required with other third parties, for example in the context of
the possible sale or restructuring of the business. We will also need to share your personal information with a
regulator or to otherwise comply with the law.
In certain cases the disclosure of your personal information to a third party as described in this paragraph 3

may involve your personal information being transferred outside of the United Kingdom. This will only be to:

a country in the European Economic Area or that is otherwise considered to have data protection rules that are equivalent to those in the United Kingdom; or
a country which is not considered to have the same standards of protection for personal data as those in the United Kingdom, in which case we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place
contractual terms approved by the relevant regulatory authorities.

For more information about the circumstances in which your personal information may be disclosed to third

parties and the safeguards we put in place to protect your personal information when we do so, please
contact us as described in paragraph 8.

4 DATA SECURITY

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. In addition, we limit access
to your personal information to those employees, agents, contractors and other third parties who have a
business need to know. 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.
You should take all reasonable steps to keep your personal information held on our IT systems secure,

including choosing a secure password for your accounts and not disclosing your passwords to anybody else.
You should use a unique password for every account.

5 YOUR RIGHTS AND RETENTION, UPDATING AND REMOVAL OF YOUR PERSONAL INFORMATION

The duration for which we retain your personal information will differ depending on the type of information
and the reason why we collected it from you. However, in some cases personal information will be retained
on a long term basis: for example, personal information that we need to retain for legal purposes will
normally be retained in accordance with usual commercial practice and regulatory requirements. Generally,
where there is no legal requirement we retain all physical and electronic records for a period of 15 years (if
you are a current employee, this will be for 15 years after your employment ends). Exceptions to this rule
are:
CCTV records which are held for no more than 30 days unless we need to preserve the records for the purpose of prevention and detection of crime;
Details regarding unsuccessful job applicants where we hold records for a period of not more than 12 months; and
Information that may be useful to a pension provider which we will retain for the period that your pension is payable.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and
you should let us know if anything changes, for example if you move home or change your phone number or
email address. You can contact us using the details in paragraph 8.
Under certain circumstances, by law you have the right to:
request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
request the erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing
of your personal data, or request that we transfer a copy of your personal information to another party,
please use the contact details in paragraph 8.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
However, we will charge a reasonable fee if your request for access is clearly unfounded or excessive.
Alternatively, we will refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right
to access the information (or to exercise any of your other rights). This is another appropriate security
measure to ensure that personal information is not disclosed to any person who has no right to receive it.

6 ENQUIRIES, ISSUES AND COMPLAINTS

In the event that you have any concerns about how we use your personal information, please contact us as
described in paragraph 8.
If you make a complaint about our handling of your personal information, it will be dealt with in accordance
with our complaints handling procedure accessible in the Employee Handbook.
If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s
Office. Please see https://ico.org.uk.for-the-public/raising-concerns/ for more information.

7 CHANGES TO THIS PRIVACY NOTICE

We reserve the right to alter this privacy notice at any time. Such alterations will be communicated via a
company wide email. You can also obtain an up-to-date copy of our privacy notice by contacting us as
described in paragraph 8. Should you object to any alteration, please contact us.

8 CONTACTING US

If you need to contact us about this notice or any other matters relating to the personal information we hold
on you, you can do so via our data protection officer, currently Caroline Christie, dpo@praeturaaf.com.

9 FURTHER INFORMATION

We hope that the contents of this privacy notice address any queries that you may have about the personal information we will hold about you and what we will do with it. However, if you do have any further queries,
comments or requests, please contact us as described in paragraph 8 above.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information,
this is a very complex area of law. More information about your legal rights can be found on the Information
Commissioner’s website at https://ico.org.uk/for-the-public/.

Back

There are two ways you can tell us what happened

Tell us anonymously or Tell us what happened