Privacy Policy Statement
Glenvardon Ltd (the Company) are a specialist subsea engineering consultancy concerned in the worldwide provision and supply of highly experienced, and qualified personnel, to clients in support of the onshore and offshore oil, gas and wind turbine energy sectors.
STATEMENT PURPOSE
We are committed to safeguarding the privacy and security of the Data Subject (hereby you / your) personal information under the control of Glenvardon Ltd. As such your personal data collected will be processed in accordance with all applicable data protection laws.
This privacy policy statement describes how Glenvardon Ltd collect, use, process and hold your personal data during, and following your association with us, in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any future amendments.
It applies to the personal data of our employees; candidates; clients; suppliers; website users; people that the Company contact in order to find out more about our candidates; and people that you indicate as emergency contacts. By presenting us with an authorised Data Consent Form it allows us to collect and process your personal data.
Glenvardon Ltd will comply with our legal obligations to you and that the personal information we hold about you will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
In doing this Glenvardon Ltd will at all times act as the Data Controller.
The legal basis for using your personal information:
Glenvardon Ltd will collect your personal data, which may include special category sensitive personal data, and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are: Consent; Legitimate Interest; Legal Obligation; and Contractual Obligation.
We will only collect, store, use, process, transfer and disclose personal data in so far as it is necessary for our legitimate interests in that we need the information in order to assess suitability for potential roles, find potential candidates, contact referees and perform services for clients.
In the event that we need to collect and hold special category personal data about you, such as health information that you or others provide, we always ask for your consent before undertaking such processing.
Why does Glenvardon Ltd require your personal data ?
To allow the company to undertake its core business and ancillary activities, and provide the best opportunity for you, we need to collect and process certain data about you.
We collect personal data from:
• Candidates, prospective and placed, for temporary, short-term or long-term roles.
• Client contacts, prospective or live, requiring / using our services.
• Supplier contacts to support our services.
• Employees, Consultants, Ad-hoc workers and Candidate Referee contacts.
What kind of personal data does Glenvardon Ltd collect?
Candidates and Staff:
In order to provide the best possible work opportunity relevant to you and your skill set, we need to collect, store and process certain general personal data about you.
Personal data that you have provided to us by corresponding with us by phone, e-mail or otherwise. This includes information you provide when submitting your CV / work history. Examples of the type of personal data you may give us:
• Personal contact details such as Name; Address; Telephone Numbers; email; Skype; etc.
• Date of Birth.
• Gender.
• Copies of your right to work documentation e.g. Passport; Visa; Work Permit.
• Bank account details; payroll records and tax status information.
• National Insurance number.
• Next of kin and emergency contact information.
• Certificates: Education; Training; Survival; Medical; Vaccination; Mist; Vantage Number.
• Referee details.
• Limited Company details.
• Extra information that you, your referees; the client may choose to tell us and / or that found out from other third-party sources e.g. Linkedin and Social Media.
Note that the above list of personal data we may collect is not exhaustive
Glenvardon Ltd may collect, and process special category or more sensitive personal data only so far as is necessary to ensure we conform to legal requirements, such as equal opportunities laws or legal obligations imposed upon us by our clients. We must have your explicit consent to collect, process and store such data and presenting us with an authorised Data Consent Form allows us to do so.
Special category data can be, for example, any of the following:
• Information about your race or ethnicity, religious beliefs, health, sexual orientation and political opinions.
• Trade union membership.
• Information about criminal convictions and offences.
Clients:
In order to provide you with the correct service and ensure our relationship runs smoothly, we usually only need to have your business contact details or the details of individual contacts at your organisation e.g. their names, telephone numbers, email addresses and company address.
Glenvardon Ltd use information about you, or individuals at your organisation, in the course of providing you services such as supplying Candidates who have the right knowledge, experience and competencies to meet the needs of your requirement.
Suppliers:
Usually all we require is business contact details and those of relevant individuals at your organisation so that we can communicate with you, such as names, telephone numbers and email addresses. We also need other information such as your bank details in order that we can pay for the services you provide (if this is part of the contractual arrangements between us).
Referees and Emergency Contacts: We only ask for very basic contact details, e.g. name, address, telephone number, email address so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
Personal data received from other sources
We may receive personal data about you from third parties, which dependent on the relevant circumstances, may include personal data received in the following situations:
• Your referees, friends, or past and present colleagues may disclose personal information about you.
• Our Clients may share personal information about you.
• We may use LinkedIn and their affiliate partners as publicly available sources of personal data for employment purposes.
• We may also receive personal information from any third parties that we work with e.g. business partners; sub-contractors; payment services.
Personal data we collect automatically:
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
How does Glenvardon use your personal data?
Glenvardon Ltd only use your personal data where the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
Internal Employees
Glenvardon Ltd can reasonably expect that your personal data will be used to carry out all administrative requirements of an employer e.g. salary payment into your bank account; calculating and making NI and tax contributions; ensuring that you have the necessary training and competency to perform your job; safeguard your personal safety, health and welfare whilst at work.
Candidates
Glenvardon Ltd will use your personal data and CV to determine your suitability for any current or future work opportunity and to contact you about same.
You can reasonably expect that Glenvardon Ltd will share certain items of your personal data, including your CV, training, and work competency records will be made available to our Client in connection with securing work for you.
For the purposes of ensuring the validity of right to work documents and security checks as may be required by our Clients and as permitted by law.
For the purposes of finding you opportunities with prospective Clients enabling them to evaluate your suitability for work assignments.
To deal with legal disputes involving you, or other employees, workers, contractors or clients, including accidents at work.
To put in place contractual arrangements and documentation once a work opportunity has been secured, including complying with our legal obligations e.g. collection of taxes or duties.
To notify you about any industry specific information that may be of interest to you and of any changes to our service. Note that the above list is not exhaustive.
Clients
As a Client, or prospective client, requesting Glenvardon Ltd to provide services then we may need to collect, use, and share your company data and / or information about individuals within your organisation to ensure that we can provide you with a suitable spread of Candidates.
Suppliers
Glenvardon Ltd require to collect certain relevant data from our Suppliers to ensure relationships run smoothly. We need supplier address details; contact information of relevant individuals, so we can communicate effectively with your organisation; and other information such as your bank details in order to pay for the services provided.
Overseas Transfer of your personal data.
Glenvardon Ltd may transfer the personal data you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding opportunities. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Security of your personal data.
Glenvardon Ltd takes every precaution to protect your personal data. All information provided is held on our database; back-ups are held off-site at a secure location.
All software used to process and store your data is password protected. Only authorised employees who need it to perform specific tasks have access to your information.
Glenvardon Ltd use all reasonable efforts to safeguard your personal information. However, be aware that the use of email / the Internet is not entirely secure and for this reason we cannot guarantee the total security or integrity of any personal information which is transferred from you or to you via email / the Internet.
How long does Glenvardon Ltd hold your personal data?
Any personal data that is required for purposes of the conclusion and execution of agreements with business clients, suppliers and business partners or for considering bids or tenders will be held during the duration of the contractual relationship and up to 6 years thereafter.
We must keep payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. Currently 3 to 6 years.
We are legally obliged to retain some types of information for longer periods of time to fulfil legal, statutory or regulatory obligations. Different pieces of information have different retention periods attached to them. This may be dictated by the type of information e.g. records of incidents, accidents, occupational health problems and complaints this will depend whether there are any outstanding legal proceedings and may be held indefinitely.
We may delete personal data from our systems if we have not had substantial contact with you for a period of 5 years unless we process and approve a Data Request Form to delete your data before this time period has elapsed.
Access to and correction of your information
Your duty to inform us of changes:
It is important that the personal data Glenvardon Ltd (the Company) hold about you (the Data Subject) is accurate and current. As such it is your duty to inform us of any change to your personal information during your working relationship with us.
Your data protection rights
By law, you have a number of data protection rights which are fully outlined on the Information Commissioner’s Office website. When it comes to your personal information you should be aware of your following rights:
The right to be informed - You have the right to be provided with concise, clear, transparent, and easily understandable information about how Glenvardon Ltd collect, lawfully process, retain, and use your personal data.
The right of access - This enables you to request access to your personal data, either verbally or in writing. Commonly referred to as a “Data Subject Access Request”.
The right to rectification - This enables you to request to have any incomplete or inaccurate personal information we hold about you corrected.
The right to erasure or the right to be forgotten - This enables you to request the deletion or removal of your personal data where there is no compelling reason for Glenvardon Ltd to keep using it. This is not an absolute right and only applies in certain circumstances.
The right to restrict processing - This enables you to request Glenvardon Ltd to restrict or to suppress further use of your personal information. When processing is restricted, we are permitted to store your personal data, but not use it further. This is not an absolute right and only applies in certain circumstances.
The right to data portability – This enables you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer your information easily between our IT environment to another safely and securely, without affecting its usability. This applies only to that information you have provided us with.
The right to object – This enables you to object to the processing of your personal data. In effect requesting Glenvardon Ltd to stop processing your personal data. The right to object only applies in certain circumstances and depends on our purpose for processing and our lawful basis for its processing. You have an absolute right to object if your personal data is processed for direct marketing purposes. However, your right is not absolute in certain other circumstances e.g. carried out: in the public interest; in our legitimate interests or those of a third party.
The right to withdraw consent - If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
Rights in relation to automated decision including profiling – Glenvardon Ltd do not carry out automated profiling of personal data and / or automated individual decision-making processing.
Managing your personal data>
If you wish to verify, correct, or request erasure of your personal data; object to the processing of your personal data; request that we transfer a copy of your personal data to another party; or request access to your personal data (Data Subject Access Request), etc., then please contact us by completing our Data Request Form and submitting it to Glenvardon Ltd, by email to: glenvardon@btinternet.com.
We will respond promptly. This will be within one month from receipt of your request. If it is going to take longer then we will advise you. Requests are usually provided free of charge; but it may be necessary to charge a reasonable fee to cover our administrative costs.
We are also entitled to refuse to act on the request if it is deemed excessive or a repetition of a previous request.
Complaints or queries:
If you are unhappy about how we have handled your personal information or have further questions on the processing of your personal data, you may contact us by using the details below:
Contact us: Glenvardon Ltd, 58 Bonnymuir Place, Aberdeen AB15 5NP Email: glenvardon@btinternet.com.
You also have the right to raise concerns with the Information Commissioners Office complaints helpline on 0303 123 1113 or at https://ico.org.uk/make-a-complaint/, if you believe that your data protection rights have not been adhered to by Glenvardon Ltd.
This notice may be subject to change over time, so please regularly check the Privacy Policy Statement, which can be found on the Glenvardon Ltd website.
STATEMENT PURPOSE
We are committed to safeguarding the privacy and security of the Data Subject (hereby you / your) personal information under the control of Glenvardon Ltd. As such your personal data collected will be processed in accordance with all applicable data protection laws.
This privacy policy statement describes how Glenvardon Ltd collect, use, process and hold your personal data during, and following your association with us, in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any future amendments.
It applies to the personal data of our employees; candidates; clients; suppliers; website users; people that the Company contact in order to find out more about our candidates; and people that you indicate as emergency contacts. By presenting us with an authorised Data Consent Form it allows us to collect and process your personal data.
Glenvardon Ltd will comply with our legal obligations to you and that the personal information we hold about you will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
In doing this Glenvardon Ltd will at all times act as the Data Controller.
The legal basis for using your personal information:
Glenvardon Ltd will collect your personal data, which may include special category sensitive personal data, and will process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are: Consent; Legitimate Interest; Legal Obligation; and Contractual Obligation.
We will only collect, store, use, process, transfer and disclose personal data in so far as it is necessary for our legitimate interests in that we need the information in order to assess suitability for potential roles, find potential candidates, contact referees and perform services for clients.
In the event that we need to collect and hold special category personal data about you, such as health information that you or others provide, we always ask for your consent before undertaking such processing.
Why does Glenvardon Ltd require your personal data ?
To allow the company to undertake its core business and ancillary activities, and provide the best opportunity for you, we need to collect and process certain data about you.
We collect personal data from:
• Candidates, prospective and placed, for temporary, short-term or long-term roles.
• Client contacts, prospective or live, requiring / using our services.
• Supplier contacts to support our services.
• Employees, Consultants, Ad-hoc workers and Candidate Referee contacts.
What kind of personal data does Glenvardon Ltd collect?
Candidates and Staff:
In order to provide the best possible work opportunity relevant to you and your skill set, we need to collect, store and process certain general personal data about you.
Personal data that you have provided to us by corresponding with us by phone, e-mail or otherwise. This includes information you provide when submitting your CV / work history. Examples of the type of personal data you may give us:
• Personal contact details such as Name; Address; Telephone Numbers; email; Skype; etc.
• Date of Birth.
• Gender.
• Copies of your right to work documentation e.g. Passport; Visa; Work Permit.
• Bank account details; payroll records and tax status information.
• National Insurance number.
• Next of kin and emergency contact information.
• Certificates: Education; Training; Survival; Medical; Vaccination; Mist; Vantage Number.
• Referee details.
• Limited Company details.
• Extra information that you, your referees; the client may choose to tell us and / or that found out from other third-party sources e.g. Linkedin and Social Media.
Note that the above list of personal data we may collect is not exhaustive
Glenvardon Ltd may collect, and process special category or more sensitive personal data only so far as is necessary to ensure we conform to legal requirements, such as equal opportunities laws or legal obligations imposed upon us by our clients. We must have your explicit consent to collect, process and store such data and presenting us with an authorised Data Consent Form allows us to do so.
Special category data can be, for example, any of the following:
• Information about your race or ethnicity, religious beliefs, health, sexual orientation and political opinions.
• Trade union membership.
• Information about criminal convictions and offences.
Clients:
In order to provide you with the correct service and ensure our relationship runs smoothly, we usually only need to have your business contact details or the details of individual contacts at your organisation e.g. their names, telephone numbers, email addresses and company address.
Glenvardon Ltd use information about you, or individuals at your organisation, in the course of providing you services such as supplying Candidates who have the right knowledge, experience and competencies to meet the needs of your requirement.
Suppliers:
Usually all we require is business contact details and those of relevant individuals at your organisation so that we can communicate with you, such as names, telephone numbers and email addresses. We also need other information such as your bank details in order that we can pay for the services you provide (if this is part of the contractual arrangements between us).
Referees and Emergency Contacts: We only ask for very basic contact details, e.g. name, address, telephone number, email address so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
Personal data received from other sources
We may receive personal data about you from third parties, which dependent on the relevant circumstances, may include personal data received in the following situations:
• Your referees, friends, or past and present colleagues may disclose personal information about you.
• Our Clients may share personal information about you.
• We may use LinkedIn and their affiliate partners as publicly available sources of personal data for employment purposes.
• We may also receive personal information from any third parties that we work with e.g. business partners; sub-contractors; payment services.
Personal data we collect automatically:
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us.
How does Glenvardon use your personal data?
Glenvardon Ltd only use your personal data where the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
Internal Employees
Glenvardon Ltd can reasonably expect that your personal data will be used to carry out all administrative requirements of an employer e.g. salary payment into your bank account; calculating and making NI and tax contributions; ensuring that you have the necessary training and competency to perform your job; safeguard your personal safety, health and welfare whilst at work.
Candidates
Glenvardon Ltd will use your personal data and CV to determine your suitability for any current or future work opportunity and to contact you about same.
You can reasonably expect that Glenvardon Ltd will share certain items of your personal data, including your CV, training, and work competency records will be made available to our Client in connection with securing work for you.
For the purposes of ensuring the validity of right to work documents and security checks as may be required by our Clients and as permitted by law.
For the purposes of finding you opportunities with prospective Clients enabling them to evaluate your suitability for work assignments.
To deal with legal disputes involving you, or other employees, workers, contractors or clients, including accidents at work.
To put in place contractual arrangements and documentation once a work opportunity has been secured, including complying with our legal obligations e.g. collection of taxes or duties.
To notify you about any industry specific information that may be of interest to you and of any changes to our service. Note that the above list is not exhaustive.
Clients
As a Client, or prospective client, requesting Glenvardon Ltd to provide services then we may need to collect, use, and share your company data and / or information about individuals within your organisation to ensure that we can provide you with a suitable spread of Candidates.
Suppliers
Glenvardon Ltd require to collect certain relevant data from our Suppliers to ensure relationships run smoothly. We need supplier address details; contact information of relevant individuals, so we can communicate effectively with your organisation; and other information such as your bank details in order to pay for the services provided.
Overseas Transfer of your personal data.
Glenvardon Ltd may transfer the personal data you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding opportunities. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Security of your personal data.
Glenvardon Ltd takes every precaution to protect your personal data. All information provided is held on our database; back-ups are held off-site at a secure location.
All software used to process and store your data is password protected. Only authorised employees who need it to perform specific tasks have access to your information.
Glenvardon Ltd use all reasonable efforts to safeguard your personal information. However, be aware that the use of email / the Internet is not entirely secure and for this reason we cannot guarantee the total security or integrity of any personal information which is transferred from you or to you via email / the Internet.
How long does Glenvardon Ltd hold your personal data?
Any personal data that is required for purposes of the conclusion and execution of agreements with business clients, suppliers and business partners or for considering bids or tenders will be held during the duration of the contractual relationship and up to 6 years thereafter.
We must keep payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. Currently 3 to 6 years.
We are legally obliged to retain some types of information for longer periods of time to fulfil legal, statutory or regulatory obligations. Different pieces of information have different retention periods attached to them. This may be dictated by the type of information e.g. records of incidents, accidents, occupational health problems and complaints this will depend whether there are any outstanding legal proceedings and may be held indefinitely.
We may delete personal data from our systems if we have not had substantial contact with you for a period of 5 years unless we process and approve a Data Request Form to delete your data before this time period has elapsed.
Access to and correction of your information
Your duty to inform us of changes:
It is important that the personal data Glenvardon Ltd (the Company) hold about you (the Data Subject) is accurate and current. As such it is your duty to inform us of any change to your personal information during your working relationship with us.
Your data protection rights
By law, you have a number of data protection rights which are fully outlined on the Information Commissioner’s Office website. When it comes to your personal information you should be aware of your following rights:
The right to be informed - You have the right to be provided with concise, clear, transparent, and easily understandable information about how Glenvardon Ltd collect, lawfully process, retain, and use your personal data.
The right of access - This enables you to request access to your personal data, either verbally or in writing. Commonly referred to as a “Data Subject Access Request”.
The right to rectification - This enables you to request to have any incomplete or inaccurate personal information we hold about you corrected.
The right to erasure or the right to be forgotten - This enables you to request the deletion or removal of your personal data where there is no compelling reason for Glenvardon Ltd to keep using it. This is not an absolute right and only applies in certain circumstances.
The right to restrict processing - This enables you to request Glenvardon Ltd to restrict or to suppress further use of your personal information. When processing is restricted, we are permitted to store your personal data, but not use it further. This is not an absolute right and only applies in certain circumstances.
The right to data portability – This enables you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer your information easily between our IT environment to another safely and securely, without affecting its usability. This applies only to that information you have provided us with.
The right to object – This enables you to object to the processing of your personal data. In effect requesting Glenvardon Ltd to stop processing your personal data. The right to object only applies in certain circumstances and depends on our purpose for processing and our lawful basis for its processing. You have an absolute right to object if your personal data is processed for direct marketing purposes. However, your right is not absolute in certain other circumstances e.g. carried out: in the public interest; in our legitimate interests or those of a third party.
The right to withdraw consent - If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
Rights in relation to automated decision including profiling – Glenvardon Ltd do not carry out automated profiling of personal data and / or automated individual decision-making processing.
Managing your personal data>
If you wish to verify, correct, or request erasure of your personal data; object to the processing of your personal data; request that we transfer a copy of your personal data to another party; or request access to your personal data (Data Subject Access Request), etc., then please contact us by completing our Data Request Form and submitting it to Glenvardon Ltd, by email to: glenvardon@btinternet.com.
We will respond promptly. This will be within one month from receipt of your request. If it is going to take longer then we will advise you. Requests are usually provided free of charge; but it may be necessary to charge a reasonable fee to cover our administrative costs.
We are also entitled to refuse to act on the request if it is deemed excessive or a repetition of a previous request.
Complaints or queries:
If you are unhappy about how we have handled your personal information or have further questions on the processing of your personal data, you may contact us by using the details below:
Contact us: Glenvardon Ltd, 58 Bonnymuir Place, Aberdeen AB15 5NP Email: glenvardon@btinternet.com.
You also have the right to raise concerns with the Information Commissioners Office complaints helpline on 0303 123 1113 or at https://ico.org.uk/make-a-complaint/, if you believe that your data protection rights have not been adhered to by Glenvardon Ltd.
This notice may be subject to change over time, so please regularly check the Privacy Policy Statement, which can be found on the Glenvardon Ltd website.
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