BACKGROUND:
GIFCO GROUP LTD (“the Company”) is an employment company which provides payroll services to its clients and workers. The Company must process personal data (including special category or ‘sensitive’ personal data) so that it can provide these services. In so doing, 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 an app portal. The Company must have a legal basis for processing your personal data. See below for more details. We will only use your personal data in accordance with the terms of this notice for the purposes of providing you with work-finding services and/or information relating to roles relevant to you.
1. Information About Us
A limited company registered in England under company number 15034523
Main trading address: 6-8 Revenge Rd, Chatham ME5 8UD
VAT number: 446571182 Email address: support@gifco.co.uk
2. What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making. Part 6 explains more about how we use your personal data for this.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
5. What Personal Data Do You Collect and How?
The Company may collect and hold some or all of the following personal data and special category or ‘sensitive’ personal data:
| Data Collected | Type of information | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new client To conduct identity and any other necessary Anti-Money Laundering (“AML”) checks on you |
Identity Contact |
Performance of a contract with you Necessary to comply with a legal obligation |
| To deliver our services To make and manage payments due to us by you To manage fees, charges and interest due on your accounts To collect and recover money that is owed to us |
Identity Contact Financial Transaction Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you To develop new ways to meet your needs To develop and carry out marketing activities To study how you use our services To provide advice or guidance about our services To improve our service offering To respond and deal with complaints To contact you within a 12-month period of you terminating or failing to use our services with offers and proposed services for you to re-engage with us or our Group. To develop and manage our business and services To test new service offerings To manage how we work with other companies that provide services to us and our clients To make recommendations and suggestions to you about services that may be of interest to you, including communicating to you about services that our other Group companies provide and those of our external business partners. To analyse any data we hold on you to understand your interests and preferences |
Identity Contact Usage Marketing and Communications Technical |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated, to study how clients use our services and ways in which to develop them, to grow and develop our business and service offerings and to inform our marketing strategy, to record the efficiency of new services, to contact you with information and services relevant to you, and to encourage you to re-engage with our services) |
| To detect, investigate, report, and seek to prevent financial crime To manage risk for us and our clients To obey laws and regulations that apply to us |
Identity Contact Financial |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (ensuring that we efficiently and effectively deal with financial crime Developing and improving our procedures and ensuring compliance with regulations) |
| To run our business in an efficient and proper way To protect our business |
Identity Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To send your contact details to external business partners who offer services that may be relevant to you To exercise our rights set out in agreements or contracts |
Contact | We will obtain your consent prior to sharing your information |
| To exercise our rights set out in agreements or contracts | Identity Contact |
Performance of a contract with you |
| Establish, exercise or defend legal claims | Identity Contact |
Necessary for our legitimate interests (to protect our business from legal claims) |
6. How Do You Use My Personal Data?
The Company needs to collect and process data in order to process pay services to you.
The Company will process your personal data for the purposes of providing you with payroll services. This includes, for example, contacting you about changes in your personal information, updating our databases, arranging payments to you, and developing and managing our services and relationship with you and our clients.
In some cases, the Company may be required to collect and process 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.
If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 11.
- The following automated decision-making method(s) may be used:
- When a user visits a website or uses our mobile app, they may be presented with a privacy notice or a cookie banner that informs them about the data collection and processing activities. The user is asked to provide consent or make choices regarding how their data will be used.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
- Socio-demographic includes details about your work or profession, nationality and any immigration information, including Biometric Residence Permits, share codes and European Settlement Status or Pre-Settlement Status
- Contact Data email address, telephone numbers, address details
- Documentary data includes details about you that are stored in documents in different formats or copies. This includes identity documentation such as passport and proof of address
- Transaction Data includes details about payments from you and other details of services you have purchased from us
- Contract Details about the services we provide to you and services you provide to your clients
- Usage Data includes data about how you use our services
- Financial payments made or received by you and your company, your bank details, credit card information
- Open data and public records includes details about you that are in public records and information about you that is openly available on the internet
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and portal
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, information you provide to us in emails, letters and over the phone
- Calls may be recorded for training and quality purposes
Where it is necessary for us to gather special categories of personal data we will only do when we have a lawful basis.
The legal bases we rely upon to offer our services to you are:
- Your consent (e.g. to register you as a new worker or to manage our relationship with you);
- Where we have a legitimate interest (e.g. managing our database and keeping work records up to date, providing payroll services to you and our clients, and contacting you to seek your consent where it is needed);
- To comply with a legal obligation that we are subject to (e.g. in order to check your entitlement to work in the UK or to comply with safeguarding requirements.
The Company will only use your personal data for the purposes for which it was originally collected, unless we reasonably believe that another purpose is compatible with those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
The Company will only hold your personal data for as long as is necessary to fulfil the purposes for which we collected it.
Different laws may also require us to keep data for different periods of time.
The Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to keep records for at least one year from:
- the date of their creation; or
- after the date on which we last provide you with work-finding services.
The Company must also keep your payroll records, holiday pay, sick pay, and pensions auto-enrolment records. These records are retained 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 and sensitive data, we will do so in line with our Data Protection Policy. Upon expiry of the period to which you have consented, the Company will seek further consent from you. Where consent is not granted, we will not continue to process your data.
8. How and Where Do You Store or Transfer My Personal Data?
Data is stored in a range of different places, including on your application record, in the Company’s candidate management systems and in other IT systems (including the Company’s email system).
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
9. Do You Share My Personal Data?
The Company will process your personal data and/or sensitive personal data with the following recipients:
- HMRC;
- Clients of the Company;
- Any applicable legal or government authorities;
- Payroll software;
When your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it. This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
[Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
11. How Do I Contact You?
If you have any questions about this privacy notice or how we handle your personal information, please contact the us by emailing support@gifco.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Notice was last updated on 18th September 2023.
