GDPR EMPLOYER PRIVACY NOTICE

What is the Purpose of this Document?

Focus Training (SW) Ltd is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).


Focus Training (SW) Ltd is a “data controller”. This means that we are responsible for decidinghow we hold and use personal information about you. We are required under data protectionlegislation to notify you of the information contained in this privacy notice. This notice applies to suppliers. This notice does not form part of any contract to provide services. We may update this notice at any time and an up to date copy can be found on our website.

It is important that you read this notice, together with any other privacy notice we may provideon specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:


1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The Kind of Information We Hold About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store, and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Bank account details.
• Location of workplace.

How is Your Personal Information Collected?
We will collect personal information in the course of job-related activities throughout the period of you working with us.


How We Will Use Information About You
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:


1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests. 

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.
Situations in Which We Will Use Your Personal Information
We need all the categories of information in the list above (see the kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursuelegitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
• Paying you.
• Administering the contract, we have entered into with you.
• Dealing with legal disputes involving our learners, including accidents at work.
• Complying with health and safety obligations.
• To prevent fraud.


Some of the above grounds for processing will overlap and there may be several grounds
which justify our use of your personal information.

If You Fail to Provide Personal Information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you (such as paying you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our learners).

Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by law.

Data Sharing
We will not share your data with any third parties unless we have your prior consent to do so. 

Why Might You Share My Personal Information with Third Parties?
We may share your personal information with third parties where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Data Security
We have put in place measures to protect the security of your information. Details of these  measures are available upon request.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention
How Long Will You Use My Information For?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your

personal data and whether we can achieve those purposes through other means, and the
applicable legal requirements.

Rights of Access, Correction, Erasure, and Restriction
Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.


Your Rights in Connection with 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”). This enables you to receive a copy of the personal information we hold
about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal information where
you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground. You also have the right to
object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to
ask us to suspend the processing of personal information about you, for example if you
want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the HR manager in writing.

No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the HR manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Officer
We have appointed a manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the HR manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the HR manager.