Company Name: Minttulip Limited (‘the Company’)
Company Contact details: Minttulip Limited WeWork 30 Stamford Street London SE1 9LQ
Company Representative: Felice Gianneri / Perrine Fernando (firstname.lastname@example.org)
Privacy notice: Privacy Notice (including for use on the company website)
Topic: Data protection
Minttulip Limited is an IT consultancy business which provides tangible and measurable business benefit to customers who decide to adopt Microsoft Online Technologies. Minttulip Limited must process personal data (including sensitive personal data) so that it can provide these services – in doing so, Minttulip Limited acts as a data controller.
You may give your personal details to the Minttulip Limited directly, such as on an application or registration form or via our website. Minttulip Limited must have a legal basis for processing your personal data we will only use your personal data in accordance with this privacy statement. At all times we will comply with current data protection laws.
Contents 1. Collection and use of personal data a. Purpose of processing and legal basis b. Legitimate interest c. Statutory/contractual requirement d. Recipients of data 2. Information to be provided when data is not collected directly from the data subject a. Categories of data b. Sources of data 3. Overseas transfers 4. Data retention 5. Your rights 6. Automated decision making 7. Cookies 8. Login files 9. Links to external sites 10. Sale of the business 11. Data security 12. Changes to this privacy statement 13. Complaints or queries
- Collection and use of personal data
- Purpose of processing and legal basis
Minttulip Limited will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of attending to you communication with us. This includes for example, contacting you and developing and managing our services and relationship with you and our clients (appropriate to you communication with us).
If you have opted-in we may also send you marketing information and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us. Where we have had a previous working relationship we will deem that you are interested in marketing information, a soft opt-in.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:
- Your consent • Where we have a legitimate interest • To comply with a legal obligation that we have • To fulfil a contractual obligation that we have with you
- Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Minttulip Limited has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
- Managing our database and records up to date appropriate to the nature of your communication with us; • Contacting you to seek your consent where we need it; • Giving you information about services that you have used from us recently; • Disclosure of information relating to potential criminal acts or security threats;
- Statutory/contractual requirement
Minttulip Limited has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) We may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work-finding services to you.
- Recipient/s of data
Minttulip Limited will process your personal data and/or sensitive personal data with the following recipients:
- Any other third parties who carry out audits to ensure that we run our business correctly • Our insurers, legal advisers • Any public information sources and third party organisations that we use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS). • Government, law enforcement agencies and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), GLAA;
- Information to be provided when data collected not from the data subject where applicable
Categories of data: The Company has collected the following personal data on you:
Personal data: • Name, mobile no., email. • Nationality (through right to work check) • Qualifications and past experience
Sensitive personal data: • Health information including whether you have a disability • Criminal conviction
Source of the personal data: The Company sourced your personal data/sensitive personal data: • A former employer • A referee whose details you previously provided to us • Cookies • Public information sources and third party organisations
- Overseas Transfers
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
- Data retention
The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.
Where the Company has obtained your consent to retain/process your personal/sensitive personal data, we will do so in line with our retention policy (a copy of which can be provided upon request). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data/sensitive personal data.
- Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the Company processes on you; • The right of access to the personal data the Company processes on you; • The right to rectification of your personal data; • The right to erasure of your personal data in certain circumstances; • The right to restrict processing of your personal data; • The right to data portability in certain circumstances; • The right to object to the processing of your personal data that was based on a public or legitimate interest; • The right not to be subjected to automated decision making and profiling; and • The right to withdraw consent at any time.
Where you have consented to Minttulip Limited processing your personal data/sensitive personal data you have the right to withdraw that consent at any time by contacting Felice Gianneri or Perrine Fernando (email@example.com). Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where Minttulip Limited will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we retain/process for you, access your personal data or exercise any of the other rights listed above.
We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. Most web browsers allow some control of most cookies through the browser settings. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.
- Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
- Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
- Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
- Data Security
Minttulip Limited takes every precaution to protect our users’ information e.g. firewalls, browser certification technology, encryption, limited access, use of passwords etc.
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
Minttulip Limited uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason Minttulip Limited cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet. If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. If you have any questions about the security at our website, you can email Felice Gianneri or Perrine Fernando (firstname.lastname@example.org)
- Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
- Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Felice Gianneri or Perrine Fernando (email@example.com)
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.