The Company is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we hold on you. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This Notice provides information to Candidates, Clients, Students & those with Parental Responsibility for the provision of Tutoring Services, Suppliers, Website Users and People whose data we receive from work seekers and employees, such as referees and emergency contacts.
The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: New Directions, Lambourne House, Lambourne Crescent, Cardiff, CF14 5GL.
The Company is a recruitment and training business which provides work-finding services to its clients and work-seekers. It also provides Tuition Services to Students, contracted with individuals with parental responsibility. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board, or third parties such as referees. The Company must have a legal basis for processing your personal data.
Throughout this notice we use terms ‘employer’, ‘employee’, and ‘employment’. This is for ease of reading and applies to all employees, agency workers, consultants, etc. whether engaged under a contract of service or contract for services.
In relation to your personal data, we will:
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services, training to support your work and to manage the employment relationship. This applies to current and former employees, workers and contractors. We need to process your data during recruitment, during your employment with us, and following the termination of your employment.
The law on data protection allows us to process your data for certain reasons only:
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
To enter into and perform your contract with us to provide the services (for example, performance and administration of the work-seeking/employment contract, ensuring you have the right skills and qualifications for the role, monitoring performance, ensuring you are paid.)
We also need to collect your data to ensure we are complying with legal requirements (for example, ensuring tax and National insurance is paid, carrying our checking in relation to your right to work in the UK, compliance with employment and equalities legislation)
We also collect data so that we can carry out activities which are necessary for our legitimate business interests and the interests of the work seeker. These include:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of your relationship with the Company as it is required to provide the services you have requested and that by processing this data it will have a minimal impact on your privacy and rights.
Special categories of data are data relating to your:
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
We will use your special category data:
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to assess suitability for a role in line with our legal obligations. The level of the criminal convictions check will be dependent on the type of role being undertaken and will be conducted in line with legal requirements
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of employment. If you do not provide us with the data needed to do this, we will unable to perform those duties, e.g. ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your employment with us in relation to our legal obligations if you do not provide us with this information, e.g. confirming your right to work in the UK or, where appropriate, confirming your legal status for carrying out your work via a criminal records check.
The personal data, including sensitive personal data, that we collect includes:
This list is not exhaustive.
The Company will process your personal data and/or sensitive personal data with the following recipients:
We may also share your data as part of a Company sale or restructure, or for other reasons to comply with legal obligations upon us.
We will never sell your data to third parties for the purposes of marketing. Where your data is transferred to a third party acting as a data processor, the Company will:
The Company will collect your personal data and will process your personal data for the purposes of providing you with work-finding services, meeting your recruitment requirements and keeping you up to data with our products and services. We may also require this information to help us to establish, exercise or defend legal claims.
The law on data protection allows us to process your data for certain reasons only:
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
To enter into and perform your contract with us to provide the services (for example, contacting you to provide work finding/recruitment service and ascertain requirements, to send you details of workers, invoices and other documents to fulfil the service.)
To meet our legal obligations, (for example ensuring we comply with employment and equalities legislation, to prevent fraud).
We also collect data so that we can carry out activities which are necessary for our legitimate business interests and the interests of Client or Work Seeker. These include:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of your relationship with the Company as it is required to provide the services you have requested and that by processing this data it will have a minimal impact on your privacy and rights.
Where one of these reasons applies we may process your data without your consent.
You may choose not to give us certain data, but you should be aware that this may prevent us from entering into a contract with you or complying with our legal obligations and this may in term affect our ability to provide the service to you.
The personal data that we collect includes:
This list is not exhaustive.
The Company will process your personal data and/or sensitive personal data with the following recipients:
We may also share your data as part of a Company sale or restructure, or for other reasons to comply with legal obligations upon us.
We will never sell your data to third parties for the purposes of marketing. Where your data is transferred to a third party acting as a data processor, the Company will:
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with tutoring services, administering the contract, and ensuring the health and safety of all service users. We need to process your data during the booking process, during provision of the services, and following the termination of the services.
The law on data protection allows us to process your data for certain reasons only:
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
To enter into and perform your contract with us to provide the services (for example, performance and administration of the service contract, processing payments, identifying student academic levels to ensure suitability of the tutoring provision, ensuring the health and safety of all parties involved within the service.)
We also need to collect your data to ensure we are complying with legal requirements (for example, ensuring the health and safety of all involved with service, complying with consumer law)
We also collect data so that we can carry out activities which are necessary for our legitimate business interests and the interests of the service user. These include:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of your relationship with the Company as it is required to provide the services you have requested and that by processing this data it will have a minimal impact on your privacy and rights.
Special categories of data are data relating to your:
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
We will use your special category data:
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights required to deliver the Service. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
We will only collect criminal conviction data where it is appropriate given the nature of the service being provided and where the law permits us. We use criminal conviction data to assess suitability for the service in line with our legal obligations. The level of the criminal convictions check will be dependent on the type of service to be delivered and will be conducted in line with legal requirements
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract to provide the Services. If you do not provide us with the data needed to do this, we will unable to perform those services
The personal data, including sensitive personal data, that we collect includes:
This list is not exhaustive.
The Company will process your personal data and/or sensitive personal data with the following recipients:
We may also share your data as part of a Company sale or restructure, or for other reasons to comply with legal obligations upon us.
We will never sell your data to third parties for the purposes of marketing. Where your data is transferred to a third party acting as a data processor, the Company will:
The Company will collect your personal data and will process your personal data for the purposes of offering services to you or obtaining support, products and services from you. We require this information in relation to our agreements with you to contact you and administer the services. We may also require this information to help us to establish, exercise or defend legal claims.
The law on data protection allows us to process your data for certain reasons only:
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
To enter into and perform your contract with us to provide the services (For example, to contact you to procure/provide services and products, administration of the service, invoicing and payment).
To meet our legal obligations, (for example ensuring we comply with employment and equalities legislation, to prevent fraud).
We also collect data so that we can carry out activities which are necessary for our legitimate business interests. These include:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of your relationship with the Company as it is required to provide the services you have requested and that by processing this data it will have a minimal impact on your privacy and rights.
Where one of these reasons applies we may process your data without your consent.
You may choose not to give us certain data, but you should be aware that this may prevent us from entering into a contract with you or complying with our legal obligations and this may in term affect our ability to provide the service to you.
The personal data that we collect includes:
This list is not exhaustive.
The Company will process your personal data and/or sensitive personal data with the following recipients:
We will never sell your data to third parties for the purposes of marketing. Where your data is transferred to a third party acting as a data processor, the Company will:
We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using the enquiry function, we will collect any information that you provide to us, for example your name and contact details.
When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, the date and the times and frequency with which you access the website and the way you browse its content.
We process your data through our websites:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of the use of our websites and that processing your data in this manner will have a minimal impact on your privacy and rights.
More specifically, we will process your data in the following ways:
Registering as either a client or candidate with New Directions requires that the registrant supply sufficient data for us to provide the required service to the registrant. This data will out of necessity include personally identifiable information, and may be used by us in order to obtain further information about a registrant (e.g. when conducting DBS checks). Please see the sections on Clients and Candidates in this Notice for further information.
Visitors who use the mail forms to contact New Directions are required to enter a valid email address, and may also be required to enter their name. This information is required to enable the recipients of messages to be able to identify the sender(s) and to permit them to provide a response. Any visitor that does not wish to disclose this information must not use the mail forms. Responsibility and/or liability for their use remains with the sender.
Emails sent via these forms, along with those sent via a standard email client, may be held on our email systems indefinitely, and may be accessible by other parties than the intended recipient (including systems administrators, managers and directors).
When someone visits this web site we collect standard server log information and some details relating to visitor behaviour (pages and files viewed, entry and exit pages, country, browser type, etc.). We do this to find out things such as the number of visitors to the various parts of the site and how they found that information which we use in order to help improve the web site. We collect this information in a way which does not identify anyone and we do not make any attempt to find out the identities of those visiting our web sites. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want or need to collect personally identifiable information through our website, we will be clear about when and why we are collecting this information. In addition to the server log files we also use Google Analytics in order to assess how our web sites are being used, and this data is treated in the same manner as that from the server logs.
To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
Certain aspects of this site may require a visitor to permit a small text file, called a cookie, to be saved to their hard drive in order for those aspects to work appropriately.
The cookies set by this web site are used to:
In accordance with the rules regarding the use of cookies, you may delete and block all cookies from this site, but parts of the site will not work appropriately. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
| Cookie | Cookie Name | Purpose | Further Information |
|---|---|---|---|
| Google Analytics |
|
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. | The cookies collect anonymous information, including the number of visitors to the site, where vistors have come to the site from and the pages they visited.
Google Analytics Privacy Centre and Google Analytics Cookie Usage. |
| Online Services | Session Cookie (PHPSESSID) | This is a session cookie which holds a number of details such as your National Insurance number (for candidates) or Client Reference number (for clients), to allow us to identify you and retrieve information associated with and for you within our online services web portal. | This is an opt-in cookie which, once set, will remain on a visitor’s computer until either the visitor clicks the Log Out link within their web portal or they close their browser window. |
| Cookie Notice | notice | This cookie is used across our sites to keep note of whether you’ve dismissed the cookie notice that appears on first and subsequent visits until dismissed, which links to this cookie policy section of our website. | This is an opt-in cookie which, once set, will remain on a visitor’s computer for up to 1 year so that there’s no need to dismiss the message on subsequent visits. |
| To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout. | |||
The Company will collect your personal data and will process your personal data for the following purposes:
The law on data protection allows us to process your data for certain reasons only:
All of the processing carried out by us falls into one of the permitted reasons.
We collect data so that we can carry out activities which are necessary for our legitimate business interests and the interests of our candidates. These include:
We believe that processing your data in this manner is a necessary, proportionate and reasonably expected outcome of the legitimate interests and activities of the Company and benefits all parties involved whilst having a minimal impact on your privacy and rights.
Where one of these reasons applies we may process your data without your consent.
The personal data that we may collect includes:
This list is not exhaustive.
The Company will process your personal data and/or sensitive personal data with the following recipients:
We will never sell your data to third parties for the purposes of marketing. Where your data is transferred to a third party acting as a data processor, the Company will:
We do not share your data with bodies outside of the European Economic Area.
In line with data protection principles, we only keep your data for as long as we need it for. Retention periods can vary depending on why we need your data. Different laws require us to keep different data for different periods of time.
For example:
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
Where the Company has obtained your consent to process your personal data and/or sensitive personal data we will do so in line with our data retention policy. 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 and/or sensitive data.
The Company will only retain your personal data for periods as set out in our Data Retention Policy, unless otherwise specified by law.
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Please be aware that you have the following data protection rights:
Where the Company have relied on your consent for processing your personal data and/or sensitive personal data you have the right to withdraw that consent at any time by contacting [email protected]. There will be no consequences for withdrawing your consent. However, in some cases we may continue to use data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights listed in this notice or to complain about this privacy notice or any of the procedures set out in it please contact: [email protected] or writing to ‘Data Protection, New Directions, Lambourne House, Lambourne Crescent, Cardiff, CF14 5GL’.
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.
The Company’s Data Protection Officer can be contacted by emailing [email protected] or writing to:
Data Protection Officer
New Directions
Lambourne House
Lambourne Crescent
Cardiff
CF14 5GL