This Privacy Notice explains how Business Control Solutions plc (‘the Company‘) handles and uses information (both hard copy and electronic) it collects about you. This notice is non-contractual and can be amended at any time.
The Company is a “data controller”. This means that the Company is responsible for deciding how to hold and use personal information about you. The Company’s address is Ground Floor, Churchgate, Peterborough, PE1 1TT.
The Company will comply with the data protection principles set out in the law when handling your personal information. Overall responsibility for monitoring compliance with data protection sits with the Data Protection Officer, whose contact details are firstname.lastname@example.org.
1. What type of information does the Company hold?
- “Personal data or information”: this means any information about an individual from which that person can be identified. It does not include data where the individual’s identity has been removed (anonymous data).
- “Special category data”: this means data about an individual of a more sensitive nature and requires a higher level of protection.
2. On what basis does the Company process your personal information?
The Company will only use your personal information when permitted by the law. Most commonly, the Company will rely on the following legal bases when using your personal information:
- Where it needs to perform the contract it has entered into with you (*).
- Where it needs to comply with a legal obligation (**).
- Where it is necessary for the Company’s legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests (***).
- Where you have provided consent (****).
We have indicated by asterisks in section 3 below the legal bases on which the Company processes your personal information. Some of the legal bases for processing will overlap and there may be several legal bases which justify the Company’s use of your personal information.
3. What personal information does the Company process?
The Company processes personal information, including basic personal information such as your name, title, job title, employer name, business contact details, business mailing address, job title and department (* and ** and ***and ****).
4. How is your information used by the Company?
The Company will use your personal information for the following purposes (this list is not exhaustive):
- Delivering consulting or software services;
- Undertaking business development activities; and
- Ensuring compliance with legal requirements and obligations to third parties.
5. What happens if you fail to provide personal information?
Where the provision of your personal data is required for the Company to enter into or carry out the performance of a contract with you or undertake business development activities, refusal to provide this personal information will prevent the Company from being able to offer its services.
6. Will you be subject to automated decision making?
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless the Company has a lawful basis for doing so and it has notified you.
7. Who will your personal information be disclosed to?
The Company will occasionally share data with trusted third parties, for example, IT service providers or payment processors. The Company only permits third parties to process your personal data for specified purposes and in accordance with its instructions. The Company requires third parties to respect the security of your data, to take appropriate security measures and to treat it in accordance with the law.
8. Will your personal data be transferred to third parties outside of the European Economic Area?
The Company may transfer personal data about you outside of the EEA. No personal information will be transferred outside of the EEA, unless the Company is certain that an adequate level of protection exists in relation to the processing of that information (e.g. EU Model Clauses).
9. How long will the Company use your information for?
The Company will only retain your personal information for as long as is necessary to fulfil the purposes it collected the personal information for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For further information on the Company’s retention of your information, please ask for a copy of the Data Protection
Policy from email@example.com.
10. What are your rights relating to your personal information?
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”).
- Request correction of the personal information that the Company holds about you.
- Request the erasure of your personal information.
- Request the restriction of and objection to processing of your personal information.
- Request the transfer of your personal information to a third party.
Request the withdrawal of your consent for processing.
Some of these rights are not automatic, and the Company reserves the right to discuss with you why it might not comply with a request.
If you want to exercise any of the above rights, please contact the Data Protection Officer in writing at firstname.lastname@example.org.
11. Who can you contact if you have concerns about the Company’s use of your personal information?
You retain the right at all times to lodge a complaint about the Company’s management of your personal data with
the Information Commissioner’s Office at https://ico.org.uk/concerns/.
If you have any concerns or queries about the Company’s use of your personal data, please contact the Data
Protection Officer in writing at email@example.com.
Anti-Slavery and Human Trafficking Policy
This policy applies to all persons employed by Business Control Solutions Plc (the Company), including all full-time and part-time employees, contractors and any employees undertaking work experience with the Company (collectively, ‘workers’). For the purposes of this policy, a ‘contractor’ describes a worker who provides their services to the Company via an intermediary.
Modern Slavery, Human Trafficking & Child Labour
Modern slavery encompasses exercising ownership over a person (slavery), imposing an obligation on a person via coercion (servitude) and forced or compulsory labour. Human trafficking involves arranging or expediting the travel of a person with the intent of exploiting them. Child labour involves the exploitation of children through any form of work that deprives them of their childhood and is physically or mentally harmful.
The Company does not fall within the scope of the Modern Slavery Act 2015 (the Act) but strictly prohibits the use of modern slavery, human trafficking and child labour in its operations. It has and will remain committed to implementing systems and controls aimed at ensuring that modern slavery, human trafficking or child labour is not taking place within the organisation. Having conducted a risk assessment of the Company’s suppliers, it was determined that the level of risk was low and therefore the Company shall prioritise its efforts towards workers directly involved in the provision of services.
The Company always endeavours to operate responsibly, ethically and in full compliance with UK legislation through the discharge of internal policies and procedures.
The Company strives to maintain high standards of ethical conduct and ensure the fair treatment of all workers throughout the organisation. The Company is committed to providing a safe working environment and ensuring the safety and wellbeing of all workers.
The Company is proud to be an accredited Living Wage Employer, offering all workers a voluntary rate of pay over and above legal requirements which is calculated according to the basic cost of living in the UK. Furthermore, all contractors and direct employees of the Company undergo thorough pre-employment screening to ensure compliance with UK labour laws. No individuals under the age of 16 are employed by or permitted to work for the Company.
As part of the Company’s commitment, all persons working for or on behalf of the Company are expected to support and uphold the below measures to safeguard against modern slavery and human trafficking:
- Demonstrate a zero-tolerance approach to modern slavery within the Company and its supply chain.
- Prevent, detect and report any case of modern slavery within the organisation or supply chain.
- Engage with relevant stakeholders and suppliers to address the risk of modern slavery in the Company’s operations and supply chain and set the expectation that suppliers are
holding their own suppliers to equally high standards.
- Adopt a risk-based approach:
– during the Company’s commercial processes when assessing third parties to determine whether the inclusion of specific contractual prohibitions against the use of modern
slavery and trafficked labour are required;
– whilst assessing the benefits of writing to suppliers requiring them to adopt the Company’s approach towards anti-slavery and human trafficking; and
– when engaging with employment and recruitment agencies to confirm their compliance with the Company’s approach.
- Conduct risk assessments and appropriate due diligence processes during which it will be considered
- Where circumstances warrant, carrying out audits of suppliers.
- Take appropriate action as soon as the Company is aware that individuals or organisations working on the Company’s behalf have breached this policy.
Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
The Company’s supplier relationships are low risk and typically involve the procurement of goods or services for internal use only, such as technology and office supplies.
The Company aims to mitigate risks when selecting and contracting with suppliers through various actions, including:
- Requiring suppliers of regularly contracted staff to confirm their workers receive the Living Wage.
- Providing educational awareness on issues relating to slavery and human trafficking to workers who directly engage with suppliers, thus helping them identify potential issues when dealing with suppliers.
- Requesting potential suppliers to provide their current anti-slavery and human trafficking policy and, where applicable, requesting confirmation of their compliance with the Act.
- Including, in standard supplier contractual templates, a clause regarding the prevention of slavery and trafficked labour.
- Conducting risk assessments of the Company’s supplier base to determine any high-risk suppliers and those which fall within the scope of the Act.