1. Purpose of this Notice
This notice sets out how AFB will handle personal data that is obtained during the course of its/his business activities. Should you have any queries about the content of this notice, please contact Adrian Bloomfield by email (firstname.lastname@example.org) or by mobile telephone 07971 079 797.
2. Identity of UK Regulator
The UK Information Commissioners Office is the supervisory authority for all matters concerning the processing of your personal data within AFB. If you have any concerns regarding the processing of your data you may contact the Information Commissioners Office (ICO) by writing to the address below. You should usually have exhausted our internal review procedures in the first instance.
Information Commissioners Office
3. Identity of the Data Controller
AFB is a Data Controller. It is the body responsible for determining the means and purposes of processing your personal data. AFB collects and processes personal data relating to report writing and consultancy services to clients. AFB is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
4. What information do we collect?
AFB collects and processes a range of information about you. This includes:
• your name, address and contact details, including email address and telephone number, date of birth and gender;
• the details, terms and conditions of your employment;
• details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the organisation;
• information about your remuneration, including entitlement to allowances and benefits such as pensions;
• details of your bank account and national insurance number;
• information about your marital status, next of kin, dependants and emergency contacts;
• information about your nationality and entitlement to work in the UK;
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
• information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments;
• your credit history
5. How do we collect personal data
AFB collects personal data in a variety of ways. For example, data is collected through application forms or CVs; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as life assurance benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments; details of any litigation and disputes concerning credit.
In a limited number of cases, AFB collects personal data about you from third parties, such as references provided by a variety of sources including credit reference agencies.
Data is stored in a range of different places, including in a secure, lockable, separate office for hardcopy documentation and other secure and encrypted IT systems.
Cookies are text files that are placed on your computer by websites that you visit. They are used to make websites work more efficiently as well as to provide website owners with information.
7. On which basis does AFB process personal data?
AFB needs to process data in conjunction with providing reports and consultancy services especially in matters of litigation. In some cases, AFB has a legitimate interest in processing personal data. AFB has a legitimate interest to process data where it is necessary for the following purposes:
• AFB uses data for a legitimate purpose to maintain business contacts and more particularly to provide reports, comments and opinions in respect of litigation and providing consultancy services.
Where AFB relies on legitimate interests as a reason for processing personal data, it has considered whether or not those interests are overridden by the rights and freedoms of the data subjects and has concluded that they are not.
AFB also processes the following special category of data:
• Credit history
8. Who has access to data?
Your information will be shared with contracted consultants including research assistants.
The Commission also shares your data with third parties that process data on its behalf. In those circumstances the data will be subject to confidentiality arrangements.
9. How does AFB protect your data?
AFB has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by contracted third party data processors in the performance of their duties.
Where the organisation 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 your personal data.
10. For how long does AFB keep data?
General business communications will be retained for a period of two years from the date of receipt.
Documents that relate to legal advice will be held for a minimum of 12 years after the case has been decided.
Financial records will be held for a minimum period of 7 years from the end of the current financial year to which they relate.
11. Your rights
As a data subject, you have a number of rights. You can:
• access and obtain a copy of your data on request;
• require the organisation to change incorrect or incomplete data;
• require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
• ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Commissions legitimate grounds for processing data.
12. What if you do not provide personal data?
Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable AFB to report and carry out its consultancy duties.