person on a phone and laptop

Introduction

Ucruit is business consultancy and provides consultation to both businesses and individuals.

The personal data that Ucruit processes to provide these services relates to its clients and other individuals as necessary.

This policy sets out Ucruit’s commitment to ensuring that any personal data, is carried out in compliance with data protection law. Ucruit is committed to ensuring that all the personal data that it processes is done in accordance with data protection law. Ucruit ensures that good data protection practice is imbedded in the culture of our staff and our organisation.

Ucruit’s other data protection policies and procedures are:
• privacy notices
• personal data breach reporting process and a breach register
• data retention policy
• IT security policies

‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation.

Scope

This policy applies to all personal data processed by Ucruit and is part of Ucruit’s approach to compliance with data protection law.

How we collect your personal data

We collect data from a wide range of sources.

We may collect data from you directly. Where you are a client or prospective client, we may also collect data from representatives or people who are providing you with other services.

We collect data from the following sources:
• From you or your representatives directly where you contact us in writing, by e-mail, in person, by telephone, through our online portal, at meetings with us or by any other method, we will collect data directly from you. This may be where you are seeking advice from us or where you are registering to attend events or subscribe to publications issued by us.
• From relatives, agents or third parties where you may be involved in a matter we are instructed in for example as an employee or employer.
• Online public sources or registers such as Companies House.
• Where you apply for a position with us, we may receive information about you from a recruitment agent, your current and/ or former employers and/ or referees.
• Providers of identity verification and compliance services.
• Devices you use when you use our service via Cookies.

Data protection principles

Ucruit complies with the data protection principles set out below. When processing personal data, it ensures that:
• it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
• it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
• it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
• it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
• it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)

Ucruit will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.

Process/procedures/guidance

Ucruit will:
• ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
• not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
• ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
• only collect and process the personal data that it needs for purposes it has identified in advance
• ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
• only hold onto your personal data for as long as it is needed, after which time Ucruit will securely erase or delete the personal data – Ucruit’s data retention policy sets out the appropriate period of time
• ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

Ucruit will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

Data Subject Rights

Ucruit has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law. All requests will be considered without undue delay and within one month of receipt as far as possible. Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:
• the purpose of the processing
• the categories of personal data
• the recipients to whom data has been disclosed or which will be disclosed
• the retention period
• the right to lodge a complaint with the Information Commissioner’s Office
• the source of the information if not collected direct from the subject, and
• the existence of any automated decision making

Rectification: the right to allow a data subject to rectify inaccurate personal data concerning them. Erasure: the right to have data erased and to have confirmation of erasure, but only where:
• the data is no longer necessary in relation to the purpose for which it was collected, or
• where consent is withdrawn, or
• where there is no legal basis for the processing, or
• there is a legal obligation to delete data

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:
• if the accuracy of the personal data is being contested, or
• if our processing is unlawful but the data subject does not want it erased, or
• if the data subject has objected to the processing, pending verification of that objection

Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format which will allow the individual to transfer the data to another data controller. This would only apply if Ucruit was processing the data using consent or on the basis of a contract.

Responsibility for the processing of personal data

The Founding Director of Ucruit takes ultimate responsibility for data protection. If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact the data protection lead in the following ways:

Name: Brian Creegan
Address: Ucruit, 3 West Craibstone Street, Aberdeen, Ab11 6YW
Email: brian@ucruit.co.uk
Telephone: 07921 628869

Monitoring and review

This policy was last updated on 24th February 2020 and shall be regularly monitored and reviewed, at least every two years.