Hublsoft is committed to being transparent about how it collects and uses personal data and to meeting its data protection obligations. This policy sets out the organisation'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, interns and apprentices, graduates, former employees, referred to as HR-related personal data. This policy applies to the personal data of our clients, prospects, third parties or other personal data processed for business purposes.
The organisation has appointed Lola Akinwunmi, Senior Customer Success Practitioner as the person with responsibility for data protection compliance within the organisation. They can be contacted at firstname.lastname@example.org. Questions about this policy, or requests for further information, should be directed to them or our People Partner.
"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.
The organisation processes HR-related personal data in accordance with the following data protection principles:
The organisation tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices and or policies. It will not process personal data of individuals for other reasons. If the organisation wants to start processing HR-related data for other reasons, individuals will be informed of this before any processing begins.
HR-related data will only be shared with third parties whereby it is required to do so, including the organisation's HR and Payroll providers or unless as set out in privacy notices. Where the organisation 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 organisation processes special categories of personal data or criminal records data to perform obligations, to exercise rights in employment law, or for reasons of substantial public interest, this is done in accordance with a policy on processing special categories of data and criminal records data.
The organisation will update HR-related personal data promptly if an individual advises that their 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 electronic format and on HR systems. The periods for which the organisation holds HR-related personal data are contained in its privacy notices to individuals.
The organisation 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.
Individuals have the right to make a subject access request. If an individual makes a subject access request, the organisation will tell them:
The organisation 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 they agree otherwise.
If the individual wants additional copies, the organisation will charge a fee, which will be based on the administrative cost to the organisation of providing the additional copies.
To make a subject access request, the individual should send the request to email@example.com. In some cases, the organisation may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify their identity and the documents it requires.
The organisation 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 request is complex, it may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell them if this is the case.
If a subject access request is manifestly unfounded or excessive, the organisation is not obliged to comply with it. Alternatively, the organisation 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 if it is made with the intention of harassing the organisation or causing disruption, or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, the organisation will notify them 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 organisation to:
To ask the organisation to take any of these steps, the individual should send the request to firstname.lastname@example.org.
The organisation takes the security of HR-related personal data seriously. The organisation 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 and any relevant parties in the proper performance of their duties. The organisation uses an online HR system and provides the relevant data security and system restrictions to relevant parties for the assurance of security of HR-related personal data.
Where the organisation engages third parties to process personal data on its behalf, such parties 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.
Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to individual rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
If the organisation discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery if the organisation is required to do so. The organisation will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
HR-related personal data may be transferred to countries outside the EEA to enable the organisation to undertake to support our international clients. Data is transferred outside the EEA on the basis of declaration of adequacy, binding corporate rules etc, please note these outlines are not exhaustive.
Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes.
Individuals may have access to the personal data of other individuals and of our customers, prospects and third parties in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff and of our customers, prospects and third parties.
Individuals who have access to personal data are required:
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation'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 organisation will provide training to all employees about their data protection responsibilities within the first 12 months of the employee’s service and at regular intervals thereafter.
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.
GDPR Statement | Last Revised - 17 September 2020