GDPR: DATA PRIVACY NOTICE FOR EMPLOYEES, CLIENTS AND SUPPLIERS 25.5.18

 Introduction

Scene2 Ltd (“We”) are committed to protecting and respecting your privacy. We hold honesty and transparency amongst our core values and we believe in investment in our client relationships, where we aim to form production partnerships.

This policy, together with our terms of use and any other documents referred to in it,  sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  The rules on the processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

  1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

  1. Who are we?

Scene2 Ltd are a design and build company.  Susan Walker, a Director at Scene2 Ltd is the data controller. This means Susan Walker supported by Scene2 Directors,  govern and decide how your personal data is processed and for what purposes. Our contact details are: susan@scene2.co.uk For all data matters contact Susan Walker, Director, Scene2 Ltd, 26 Horsecroft Road, Harlow, Essex, CM19 5BH.

  1. The purpose(s) of processing your personal data

We use your personal data for;

  • Employees only for Human Resources purposes, to manage our employees, maintain our own accounts and records, inform individuals of news, events, activities and HMRC purposes only.
  • Clients & Suppliers – You may give us information about you by filling in forms on our site scene2.co.uk (our site) or by corresponding with us by phone, e-mail, whatsapp, social media interaction or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product or service, place an order, participate in discussion boards or other social media functions on our platforms, enter a competition, promotion or survey online, when you report a problem with our site and request a quote from us.
  1. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

  • Employees only Personal data – full name, copy of passport & number, home address or private email address, phone numbers, NI number, copy of driving license & number, details for your next of kin, past employment references, qualifications and medical records. Online identifiers include IP addresses and cookies. We have obtained your personal data from your completed and signed starter forms and documentation you have provided us with.
  • Clients & Suppliers only – Name, position, employer, phone numbers inc. personal mobile, email addresses, company addresses, supervisor names and positions, names and positions of colleagues within your company along with copies of NDA & Terms and Conditions of contracts, record of quotes provided, previous work and contracts we have entered into with you and value of that business along with your credit rating score via publicly available sources.
  1. What is our legal basis for processing your personal data (article 6 of GDPR)?

Our lawful basis for processing your general personal data:

  • Processing data necessary for the performance of a contract with the data subject or to take steps to enter into a business contract and agreement of Terms and Conditions of Contracts and/or
  • Processing necessary for compliance with a legal obligation – HMRC and agreement of Terms & Conditions of Business and/or
  • Processing data where Consent of the data subject is given directly or
  • Processing data for potential engagement in a contract of business as a B2B legitimate interest
  • Processing of B2B data under PECR regulations
  1. How do we record this data?
  • Employees only Personal data – full name, copy of passport & number, home address or private email address, phone numbers, NI number, copy of driving license & number, details for your next of kin, past employment references, qualifications and medical records. Online identifiers include IP addresses and cookies data is all stored in:

HR Software – you have a personal login and password for this site where you can access your data

Paper copies of Data Protection Consent form, Terms and Conditions of Employment, Employee New Starter form, Confidentiality Letter, Medical Questionnaire, Passport, Driving License, Health & Safety Induction Checklist and Mileage Claim Responsibility Form, CV, Appraisal notes and P45/P46 which are stored in locked filing cabinet in the locked Scene2 Finance Office.

  • Clients & Suppliers only – Name, position, employer, phone numbers inc. personal mobile, email addresses, company addresses, supervisor names and positions, names and positions of colleagues within your company, record of quotes provided, record of services provided or enquired after, previous work and contracts we have entered into with you and value of that business are all stored on our secure accounting and Sales and Marketing Software which is accessed via personal login by authorised Scene2 employees only. Copies of signed NDA & Terms and Conditions of contracts along with all sales invoices are all stored either electronically on Scene2 network, which is accessed by authorised Scene2 employees only via personal login and/or paper copies are stored in secured location within Scene2 premises.
  • Monitoring of Communication

From time to time, we monitor communications – calls, text messages, emails, social media content and other communications in relation to dealing with customers.  We do this for governance of regulatory compliance, self-regulation practice, crime prevention and conduct to protect the security of our communication systems and procedures. To check for obscene or profane content, quality control and staff training and this is justified by our legitimate interests or our legal obligations/NDA with clients.

  1. Sharing your personal data

Your personal data will be treated as strictly confidential.  For Employees only will be shared only with Scene2 Accountants who are employed to operate Scene2 Ltd payroll system, HMRC, Scene2 Ltd Directors, Financial & HR departments. For Clients and Suppliers with Scene2 Accountants and Scene2 Ltd employees only. Where data has been shared on WhatsApp for ongoing progress reporting purposes, we will delete any relevant groups as soon as the project has ended or upon your request, whichever falls sooner.

  1. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary.

For Employees only we only retain your data for the period of your employment for HR, financial legal and safeguarding purposes. Following the termination of your employment your data is securely archived and stored in case of any legal and HR safeguarding issues for a period of 7 years in line with statutory archiving legislation.

For Clients and Suppliers we retain your data for the period of engagement in a contract of business and/or period of potential engagement in a contract of business as a legitimate interest. Your data will be securely stored with limited access given to relevant Scene2 Ltd employees and New Business Consultants only as engaged by Scene2 Ltd, until you notify us otherwise in writing, at which time your data will be permanently removed from our records and destroyed at your request. (see 9.)

  1. Providing us with your personal data

For Employees – we require your personal data as it is a statutory and contractual requirement to enter into an employment contract with Scene2 Ltd.

For Clients and Suppliers – we require your data to enable us to communicate with you, enter into and fulfil business contracts with you and provide you with ongoing information on Scene2 Ltd as a legitimate interest.

  1. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data where applicable i.e. where processing is based on legitimate interests or the performance of a task in the public interest/exercise of official authority; direct marketing and processing for the purposes of scientific/historical research and statistics.
  1. Transfer of Data Abroad

We do not transfer personal data outside the EEA without your prior consent.  We will only request this in relation to making travel bookings for international business only where appropriate.

  1. Automated Decision Making

We do not use any form of automated decision making in our business.

  1. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

  1. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

  1. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact Susan Walker – Director Scene2 Ltd susan@scene2.co.uk.  If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.