Every day our business will receive, use and store personal information about our customers, suppliers and colleagues. It is important that this information is handled lawfully and appropriately in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’).
We take our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.
This policy, and any other documents referred to in it, sets out the basis on which we will process any personal data we collect or process.
This policy does not form part of any employee’s contract of employment and may be amended at any time. Shane Kavanagh, CEO, is responsible for ensuring compliance with the Data Protection Requirements and with this policy.
Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager via firstname.lastname@example.org, or reported in line with the Crussh’s Whistleblowing Policy or Grievance Policy.
Anyone processing personal data, must ensure that data is:
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the Data Protection Requirements, we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
In the course of our business, we may collect and process the personal data set out in the Schedule 1. This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, location data, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).
We will only process personal data for the specific purposes set out in the Schedule 1 or for any other purposes specifically permitted by the Data Protection Requirements. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.
If we collect personal data directly from an individual, we will inform them about:
If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible (in addition to telling them about the categories of personal data concerned) but at the latest within 1 month.
We will also inform data subjects whose personal data we process that we are the data controller with regard to that data and our contact details are email@example.com, the Data Protection Compliance Manager(s) can be contacted via this address.
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
We will not keep personal data longer than is necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.
We will process all personal data in line with data subjects’ rights, in particular their right to:
We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental or unlawful destruction, damage, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed.
We will put in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction.
Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
Security procedures include:
We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organisation, provided that one of the following conditions applies:
Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.
We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Individuals must make a formal request for information we hold about them. Crussh employees who receive a request should forward it for the attention of the Crussh Data Protection Compliance Manager via firstname.lastname@example.org immediately.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the
following conditions are met:
Where a request is made electronically, data will be provided electronically where possible.
Our employees will refer a request to Ben Tyrer for assistance in difficult situations.
We reserve the right to change this policy at any time. Where appropriate, we will notify changes by mail or email.
|Type of data||Type of data subject||Type of processing||Purpose of processing||Type of recipient whom personal data is transferred||Retention schedule|
|Contact details||Employee||Contractual||Personnel file & Payroll||HR software system & HMRC||7 years post-employment|
|Pay details||Employee||Contractual||Personnel file||HR software system||7 years post-employment|
|Annual leave details||Employee||Contractual||Personnel file||HR software system||7 years post-employment|
|Sick leave/ Absence details||Employee||Contractual||Personnel file||HR software system||7 years post-employment|
|Performance details||Employee||Contractual||Personnel file||HR software system||7 years post-employment|
|Gender||Employee||Legal compliance||Personnel file||HR software system||7 years post-employment|
|Contact details||Successful and unsuccessful job applicants||Contractual||Recruitment||HR software system||12 months post- application, or 7 years post-employment|
|Qualifications & Employment history||Successful and unsuccessful job applicants||Contractual||Recruitment||HR software system||12 months post- application, or 7 years post-employment|
|Ethnicity & Disability status||Successful and unsuccessful job applicants||Legal compliance||Recruitment||HR software system||12 months post- application, or 7 years post-employment|
|Immigration/ residence status||Successful job applicants||Legal Compliance||Recruitment||HR Software system & Right to work compliance system||7 years post-employment|
|Training records||Employees||Contractual||Learning & Development||LMS platform provider & HR software system||7 years post-employment|
|Bank and tax details||Employees||Legal obligation||Payroll||HMRC & Payroll provider||7 years post-employment|
|Pension details||Employees||Legal obligation||Payroll||HMRC & Payroll provider||75 years post-employment|
|Contact details||Customers & suppliers||Contractual||Delivery accounts and supplier use||External accountant and accounting software provider||While in use and 3 years after final use|
|Bank details||Customers & suppliers||Contractual||Delivery accounts and supplier use||External accountant and accounting software provider||While in use and 3 years after final use|
|Contact details, Device ID, IP address and Geographical data||Customers||Contractual||Use of Crussh app||N/A||While in use. Destroyed upon closing account|
|Contact details||Customers||Consent||Direct marketing||Mail list management software providers||While in use. Then archived and kept for 2 years.|
|Contact details||Customers||Legitimate interests||Customer feedback||Electronic survey & email client providers||Emails kept until case is closed, surveys kept 2 years post completion|