The Keyholding Company
Service Partner Operative Privacy Notice
The Keyholding Company (TKC) is aware of its obligations under the General Data Protection Regulation (GDPR) and domestic data protection legislation, and is committed to processing your data securely and transparently. This privacy notice sets out, in line with current data protection obligations, the types of data that we hold on you as an operative completing jobs on behalf of TKC. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
TKC is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: The Keyholding Company, email@example.com / 0370 770 6880
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
We hold many types of data about you, including:
- your personal details including your name, date of birth, email address, phone numbers
- documentation relating to your right to work in the UK
- documentation relating to your SIA licence
- Login details to TKC systems
- Geolocation data (while using TKC applications)
How we collect your data
We collect data about you in a variety of ways and this will usually start when you sign up to use our systems (e.g. Chase). We also might verify data from external sources (e.g. SIA licence details). Personal data is kept within TKC IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- in order to perform the employment contract that we are party to
- in order to carry out legally required duties
- in order for us to carry out our legitimate interests
- to protect your interests and
- where something is done in the public interest
- where we have obtained your consent.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
Sharing your data
We may share your data with third parties (clients) in order for you to perform jobs on behalf of TKC.
We do not share your data with bodies outside of the European Economic Area.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. This includes Cryptographic, User Access Control policies to ensure that your data is secure within TKC IT systems.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with current data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your employment with your TKC Service Partner. Though in some cases we will keep your data for a period after your employment has ended. Retention periods can vary depending on why we need your data, as set out below:
We store data about Service Partner operatives for 1 year after contract termination. Or before if an Ad-hoc request is received.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. You can read more about this in our subject access request policy which is available from [insert details]
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact firstname.lastname@example.org
Last Reviewed: 1/2/2023