JNP Group Privacy Notice
DATA PROTECTION POLICY
Date: January 2021
The Company is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out the Company’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to the personal data of job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees, referred to as HR-related personal data. This policy does not apply to the personal data of clients or other personal data processed for business purposes.
The Company has appointed Colin Cook as the person with responsibility for data protection compliance within the Company. He can be contacted via Email. Questions about this policy, or requests for further information, should be directed to him and the HR Manager.
“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.
“Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data protection principles
The Company processes HR-related personal data in accordance with the following data protection principles:
- The Company processes personal data lawfully, fairly and in a transparent manner.
- The Company collects personal data only for specified, explicit and legitimate purposes.
- The Company processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- The Company keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- The Company keeps personal data only for the period necessary for processing.
- The Company adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
The Company tells individuals the reasons for processing their personal data, how it uses such data and the
legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where the Company relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
Where the Company processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data.
The Company will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual’s personnel file (in hard copy or electronic format, or both), and on HR systems. The periods for which the Company holds HR-related personal data are contained in its privacy notices to individuals.
The Company keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
As a data subject, individuals have a number of rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, the Company will tell him/her:
- whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
- for how long his/her personal data is stored (or how that period is decided);
- his/her rights to rectification or erasure of data, or to restrict or object to processing;
- his/her right to complain to the Information Commissioner if he/she thinks the Company has failed to comply with his/her data protection rights; and
- whether or not the Company carries out automated decision-making and the logic involved in any such decision-making.
The Company will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.
To make a subject access request, the individual should complete the Company’s form for making a subject access request and send to the HR Manager. In some cases, the Company may need to ask for proof of identification before the request can be processed. The Company will inform the individual if it needs to verify his/her identity and the documents it requires.
The Company will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the Company processes large amounts of the individual’s data, it may respond within three months of the date the request is received. The Company will write to the individual within one month of receiving the original request to tell him/her if this is the case.
If a subject access request is manifestly unfounded or excessive, the Company is not obliged to comply with it. Alternatively, the Company can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the Company has already responded. If an individual submits a request that is unfounded or excessive, the Company will notify him/her that this is the case and whether or not it will respond to it.
Individuals have a number of other rights in relation to their personal data. They can require the Company to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override the Company’s legitimate grounds for processing data (where the Company relies on its legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the Company’s legitimate grounds for processing data.
To ask the Company to take any of these steps, the individual should send the request to the HR Manager.
The Company takes the security of HR-related personal data seriously. The Company has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. All data on employees is restricted to the HR Manager, Practice Manager, Accounts Assistant, Local Office Directors and Office Managers.
The Company’s HR Database and Payroll System has restricted access to the HR Manager, Practice Manager and Accounts Assistant and these systems are secured with passwords.
Data on rail employees is restricted to the Rail Manager, Rail Associates, HSQE Manager and Office Managers.
Where the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
International data transfers
The Company will not transfer HR-related personal data to countries outside the EEA.
Individuals are responsible for helping the Company keep their personal data up to date. Individuals should let the Company know if data provided to the Company changes, for example if an individual moves house or changes his/her bank details.
Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the Company relies on individuals to help meet its data protection obligations to staff and to customers and clients.
Individuals who have access to personal data are required:
- to access only data that they have authority to access and only for authorised purposes;
- not to disclose data except to individuals (whether inside or outside the Company) who have appropriate authorisation;
- to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
- not to remove personal data, or devices containing or that can be used to access personal data, from the Company’s premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
- not to store personal data on local drives or on personal devices that are used for work purposes; and
- to report data breaches of which they become aware to Colin Cook immediately.
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the Company’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
The Company will provide training to all individuals about their data protection responsibilities as part of the induction process.
Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.
SIGNED BY THE EXECUTIVE WITH OVERALL RESPONSIBILITY FOR DATA PROTECTION:
Date: January 2021
Information provided to us via cookies
Our web site uses one cookie which is to track which web server is being used during your visit. This improves the performance of our website. You can disable it using your browser options. A cookie is a small data text file sent from a server computer during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by web sites to simulate a continuous connection to that site.
How we use your data
- To perform the services as instructed by you directly or via a third party.
- To keep you informed and updated about JNP Group news and services.
- To promote our services to you.
- To administrate your account
Who we share your data with
We do not share your data with any other company without your prior consent except those processors we use for our business operations and to fulfil a contract or legal obligation.
- Microsoft® UK who provide our office & email system hosting
- UK based data centreshosting financial and client tracking systems
- Worldpay™ who process credit card payments on our behalf
- Paragon Internet Group Ltd who host our website
- IT infrastructure maintenance provider
- Associatesand contract consultants providing services to uson your behalf
- Service providers such as land drilling
- Statutory Authorities and Agenciessuch as the Environment Agency, Coal Authority
- Local Authority departments such as Building Control and Highways
- Other Government Agencies such as the Land Registry
- Private Infrastructure organisations the National Grid and gas or electricity utility companies
Servers where your personal data is stored and processed are located in the European Economic Area with the exception of transactional card payment data which may be processed in the USA by Worldpay who adhere to the EU-US Privacy Shield framework.
How we keep your personal information safe
We take our obligations to keep your personal data safe and secure very seriously and hold Cyber Essentials certification.
How to keep your personal information up-to-date
It is important for both you and us that your personal information is correct. If you believe this is not the case, please e-mail the amended details to firstname.lastname@example.org and we will contact you to verify your identity and then update your details.
How you can find out about the information we hold about you
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us using the contact details in this notice. We will get in contact to verify your identity and if we do hold information about you we will:
- give you a description of it
- tell you why we are holding it
- tell you who it could be shared with
- let you have a concise and clear copy of the information
Our legal basis for processing your personal information
Most of our processing is on the basis of “performance of a contract” or to comply with a “legal obligation” such as the Party Wall etc Act 1996 and the Building Regulations 2010. For promoting our services to organisations such as limited companies and incorporated partnerships and for processing data in relation to Statutory Authorities, Local Authorities and Government Agencies we rely on “Legitimate Interest”. For promoting our services to sole traders and non-incorporated organisations we rely on consent.
Asking us to suppress or remove your personal information
Should you not want to receive marketing information from us in future then you can click the unsubscribe link on our marketing emails or send your details to email@example.com and we will suppress your details. If you object to us processing your personal information you can tell us, and we will stop – unless we have overriding legal reasons. If you would like us to remove your information entirely then please let us know. Please remember that we do often have obligations to retain your data for example for compliance, regulatory, liability or warranty reasons. If this is the case, we will explain the reasons to you. If not, we will remove your information – but we would encourage you to let us use it for suppression purposes only.
What to do if you have a complaint
If you have a complaint,please contact us at firstname.lastname@example.org who will deal with your request promptly. If you are still not satisfied with the way your complaint was handled, you can refer your complaint to UK Information Commissioner’s Office. https://ico.org.uk/concerns/
Links to other websites
We link our website directly to other sites such as Facebook and LinkedIn. This privacy notice does not cover the links within our site linking to other websites and organisations. We encourage you to read the privacy statements on the other websites you visit.
Sale of business
Should JNP Group Consulting Engineers Limited be sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers’ advisers and will be passed on to the new owners of the business. We will notify you should this occur, and you will have the opportunity to request suppression or deletion at that time.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 31st May 2018
Legal Information about JNP Group
We are the JNP Group Consulting Engineers Limited
- JNP Group,John Newton & Partners and Barneveldare trading names of JNP Group Consulting Engineers Ltd.
- Our company registration number is 10234789
- Our office is registered at Bourbon Court, Nightingales Corner, Amersham, HP7 9QS
- Our VAT number is 248278082
PLEASE NOTE: The information provided, and the opinions expressed in this document represent the views of DQM GRC. They do not constitute legal advice and cannot be construed as offering comprehensive guidance to the GDPR, Privacy and Electronic Communications Regulations (PECR) or other statutory measures referred to in the course of the consultation. The views provided depend upon the information given and are given in the context of guidance and interpretation at the time of writing. Please obtain qualified legal advice where appropriate.