Data Privacy Notice
Pelham Street collects and processes personal information, or personal data, relating to its employees, workers and contractors to manage the working relationship. This personal information may be held by Pelham Street on paper or in electronic format.
Pelham Street is committed to being transparent about how it handles your personal information, to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal information both during and after your working relationship with Pelham Street. We are required under the GDPR to notify you of the information contained in this privacy notice.
This privacy notice applies to all current and former employees, workers and contractors. It is non-contractual and does not form part of any employment contract, casual worker agreement, consultancy agreement or any other contract for services.
If you have any questions about this privacy notice or about how we handle your personal information, please contact [email protected].
Data protection principles
Under the GDPR, there are six data protection principles that Pelham Street must comply with. These provide that the personal information we hold about you must be:
- Processed lawfully, fairly and in a transparent manner.
- Collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
- Adequate, relevant and limited to what is necessary in relation to those purposes.
- Accurate and, where necessary, kept up to date.
- Kept in a form that permits your identification for no longer than is necessary for those purposes.
- Processed in a way that ensures appropriate security of the data.
Pelham Street is responsible for, and must be able to demonstrate compliance with, these principles. This is called accountability.
The type of personal information we collect
We currently collect and process the following information:
- Place of work
- Job role
- Email address (es)
- Phone number (s)
- Address (es)
- Employment history and experience
- Stakeholder feedback and appraisals
- Psychometric and other assessment reports
- Development plans developed for the purposes of services undertaken by Pelham Street
- If you are an employee or a consultant employed by us:
- your CV and details of your skills, qualifications, work history and
- experience and your professional memberships
- your bank account details
- your photograph.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly for one of the following reasons:
- To enable Pelham Street to perform the services we are contracted to perform
- To contact anyone to whom it is agreed we will provide services
- To complete and send terms and conditions/contracts/agreements
- To issue a purchase order, quote or invoice.
We may also collect additional personal information as agreed in any statement of work agreed with Pelham Street and any entity to whom we are providing services. Stakeholder feedback is confidential and non-attributable.
We also receive and gather personal information indirectly, from the following sources in the following scenarios:
- Organisations and individuals within them – to enable Pelham Street to contact anyone to whom it is agreed we will provide services
- External introductions by third party contacts of Pelham Street, including consultants who work with Pelham Street
- From public sources such as LinkedIn and the internet
Why and how do we use your personal information?
We will only use your personal information when the law allows us to. We will use your personal information in one or more of the following circumstances, known as the legal bases for processing:
- where we need to do so to perform the agreement, consultancy agreement or contract for services we have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party), and your interests or your fundamental rights and freedoms do not override our interests.
Please note that we may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.
Who has access to your personal information?
Your personal information may be shared internally within Pelham Street and Pelham Street may also share your personal information with third-party service providers (and their designated agents), including:
- for employees:
- external organisations for the purposes of conducting pre-employment reference and employment background checks
- payroll providers
- benefits providers and benefits administration, including insurers
- pension scheme provider and pension administration
- occupational health providers
- external IT services
- external auditors
- professional advisers, such as lawyers, accountants and HR consultants
- consultants and service providers employed by Pelham Street for the purposes of the delivery of services by Pelham Street.
How does Pelham Street protect your personal information?
Pelham Street has put in place measures to protect the security of your personal information. It has internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities.
Where your personal information is shared with third-party service providers, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and we do not allow them to use your personal information for their own purposes.
Pelham Street also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.
For how long does Pelham Street keep your personal information?
Pelham Street will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, tax, health and safety, reporting or accounting requirements.
Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems within 6 months after the end of any relevant engagement, and we will also require third parties to destroy or erase such personal information where applicable. Any contractual agreements will be retained for 6 years after the end of the contractual arrangement and securely and effectively destroyed or permanently erased from our IT systems within 7 years after the end of the contractual arrangement.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at [email protected] if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected]
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk