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Clean Sweap Domestic Services

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with a personal touch

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PRIVACY POLICY

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Clean Sweep SW Ltd Privacy Policy

 

Introduction

 

This Privacy Statement explains in detail the types of personal data we may collect about various individuals when they interact with us. It also explains how we’ll store and handle that data, and keep it safe.

 

We know that there’s a lot of information here but we want individuals to be fully informed about their rights, and how Clean Sweep uses personal data.

 

Our overriding principle is that we will only use personal data in a way that an individual would reasonably expect. For example, client email addresses only to communicate out the service we provide or staff ID documents to prove right to work in the UK.

 

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

 

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish. It will always be on our website.

 

The Legal Basis for Processing Personal Data

The GDPR regulations set out a number of different reasons for which a company may collect and process personal data, including:

 

Consent

In specific situations, we can collect and process personal data with the individual’s consent.

 

For example, when a staff member ticks a box to confirm they are happy to share details of their DBS checks with clients.

 

Contractual obligations

In certain circumstances, we need personal data to comply with our contractual obligations.

 

For example, if a client requires a monthly audit emailed to them we will need to collect their email address. If a member of staff joins our team we will need to collect their bank details to pay them.

 

Legal compliance

If the law requires us to, we may need to collect and process personal data.

 

For example, we must collect and maintain copies of passports and/or visas to meet the Home Office requirements for proof to work in the UK.

 

Legitimate interest

In specific situations, we require personal data to serve the legitimate interests of an individual or Clean Sweep. This will always be in a way which would reasonably be expected as part of running our business and which does not materially impact that individual’s rights, freedom or interests.

 

For example, we will maintain email addresses of people who have asked for a quotation from us in the past and continue to use that data to stay in touch for when our services are needed. That will always be through personal contact, not through mass emails.

 

When do we collect personal data?

We collect data from Clients, Potential Clients and Suppliers:

* from publicly available sources such as Google, Companies House and other public sources

* from individuals during telephone conversations, face-to-face meetings, email exchanges, letter correspondence and social media interactions

* from our online quote request form

* during our site survey and quotation process

 

We collect data from job applicants:

* from the online and/or paper application form

* from recruitment consultants

* from direct approaches by email and post

* from individuals during telephone conversations, face-to-face meetings, email exchanges, letter correspondence and social media interactions

* through phone and face-to-face interviews

* from referees provided by the Job Applicant

 

We collect data from Employees and Sub-Contractor Employees:

* during the on-boarding process

* during day-to-day HR processes (e.g. appraisals, disciplinaries, etc)

* from individuals during telephone conversations, face-to-face meetings, email exchanges, letter correspondence and social media interactions

* from emails held on our email server

 

We collect data from Competitors:

* from publicly available sources such as Google, Companies House and other public sources

* from 3rd party data providers

* from individuals during telephone conversations, face-to-face meetings, email exchanges, letter correspondence and social media interactions

 

We collect data from office visitors:

* from their arrival at reception

* in the event of a RIDDOR incident

 

We collect data from website visitors:

* from cookies

* from 3rd party marketing providers including Google and Lead Forensics

 

What personal data do we collect?

From Clients, Potential Clients and Suppliers:

names, phone numbers, addresses, email addresses, and social media accounts

 

From Job Applicants:

 

* personal information including nationality, normal CV information and application form answers

* correspondence

* information about their current package

* interview notes

* medial history

* referee responses

* psychometric test results

 

From employees and sub-contractor employees – same as from job applicants plus:

* proof of ID and right to work in the UK

* proof of address

* P45, NI number, tax code and other normal tax information

* bank account details

* emergency contacts

* normal HR records

* correspondence

* emails sent and received

* details of any RIDDOR incidents on client sites

* timesheet data of hours worked as well as authorise and unauthorised absence

 

From competitors:

* individual names, phone numbers, email addresses and social media accounts

* correspondence

 

From website visitors:

* device and IP address information held in a cookie

* personal details entered into web forms

 

How and why do we use personal data?

For Clients:

* to deliver our service and maintain customer satisfaction

* to send invoices and conduct credit control

* to handle customer service queries

 

For potential clients

* to market and sell our services to appropriate people

 

For suppliers

* to manage the goods & services we receive from our suppliers

* to query invoices and make payments

 

For job applicants:

* to assess suitability for the role

 

For employees and sub-contractor employees:

* to verify the employee is who they say they are

* to verify their right to work in the UK

* to ensure the correct hours are delivered to clients

* to pay them for the work done and deduct appropriate tax at source

* to manage their Health and Safety

* to record any details of RIDDOR incidents

* to manage them in their day-to-day job and to develop them as individuals

* to keep them informed of important news and events at Clean Sweep

* to meet the safeguarding requirements of our clients

 

For website visitors:

* to identify visitors who have subsequently contacted us by phone or webform

* to gather personal details to allow us to make contact as requested

 

How do we protect personal data?

We take data security very seriously. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. This includes:

 

* Holding all electronic files on password protected secure email and file servers and on locked personal IT devices with planned and controlled access rights

* Designing a file storage structure that ensures appropriate documents are only accessed by members of our team that need access

* Establishing a strong password policy with regular forced change of passwords

* Holding paper documents in locked filing cabinets on site

* Maintaining a GDPR risk register that assesses risk of data breaches and drives mitigating action

 

Clean Sweep combines technical and physical safeguards with employee policies and procedures to protect your information. We work to protect your personal information during transmission by using Secure Sockets Layer software, which encrypts the information that you provide online at our website. We will use commercially reasonable efforts to protect your information. We will also continue to assess new technology for protecting information and upgrade our information security systems when appropriate.

 

Further, we permit only authorized Clean Sweep employees to access any personal information. If an employee misuses personal information, we may take disciplinary action, up to and including termination of employment. If any third party individual or organization misuses personal information, we will take action, up to and including termination of any agreement between Clean Sweep and that individual or organization.

 

Data Integrity

Clean Sweep processes personal information only for the purposes it was originally collected and in accordance with this Privacy Statement. Clean Sweep takes commercially reasonable steps to ensure that the personal data is relevant, reliable for its intended use, accurate, complete, and current for the purposes for which it is used. CLEAN SWEEP retains information for as long as reasonably required for business purposes or as reasonably required to comply with our legal obligations.

 

Cookies and logs

We collect information related to your use of our website using cookies and log information.

Cookies are small files containing strings of text stored on your computer. Clean Sweep uses cookies to authenticate you as a user when you log in, track your session, deliver content specific to your preferences and interests, and provide other functions.

Log information may include web requests, Internet Protocol address, operating system, browser type, browser language, date and time of your request, and cookies that may uniquely identify your browser. Clean Sweep uses this information to enhance the functionality of the website and to make your access more convenient, secure, and efficient.

We also use information gathered from logs and cookies to monitor website performance; improve website design, functionality, and security; and assemble web analytics and activity trends. Clean Sweep retains such information for as long as reasonably required for business purposes or as reasonably required to comply with our legal obligations.

 

Who do we share personal data with?

We sometimes share your personal data with trusted third parties. For example, with our accountants or lawyers.

 

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

 

* We provide only the information they need to perform their specific services.

* They may only use your data for the exact purposes we specify in our contract with them.

* We work closely with them to ensure that your privacy is respected and protected at all times.

* If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

 

When might we disclose personal information?

* When required by law or by an order or requirement of a court, administrative agency, or other government entity, or by court rules concerning the production of records

* If we have reasonable grounds to believe that use or disclosure is necessary to protect the rights, privacy, property, or safety of our users or other people

* If we have reasonable grounds to believe that the information relates to the breach of an agreement or violation of the law that has been, is being, or is about to be committed

* If it is necessary for fraud protection, risk reduction, or the establishment or collection of funds owed to us

* If it is necessary to enforce or apply our legal agreements, to pursue remedies, or to limit damages to Clean Sweep

* If the information is public

* If you have provided consent or with your direction

* If other reasons allow it or other laws require it.

 

When we are required or permitted to disclose information, we will not disclose more information than is necessary to fulfil the disclosure purpose.

 

Examples of the kind of third parties we work with are:

* IT companies who support our website and other business systems

* Professional advisors, consultants and our banks

* Government agencies such as HMRC, the Home Office and law enforcement/regulators bodies

* 3rd party DBS checking companies

* Recruitment companies and consultants

* Web marketing companies such as Google and Facebook

* We will never share your data with third parties for their own purposes (e.g. other companies who want to sell to you).

 

Where Personal Data May Be Processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

 

If a 3rd party supplier of ours is based outside the UK (e.g. Google) then personal data may be collected and transferred outside the EEA.

 

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us.

 

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

 

What Rights Do Individuals Have Over Their Personal Data?

Outlined below is an overview of individuals’ rights under GDPR. Individuals have the right to request:

 

* Access to the personal data we hold about you, free of charge in most cases

* The correction of your personal data when incorrect, out of date or incomplete

* The deletion of your data where applicable

* That we stop processing your personal data

* To object to the processing of your data for legitimate reasons or direct marketing

To exercise your rights above please contact Clean Sweep SW Ltd, Exeter Estates, Peamore, Alphington, Exeter EX2 9SL or email info@cleansweepdomestic.co.uk

 

If we choose not to action your request we will explain to you the reasons for our refusal.

 

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

 

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.

We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

 

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

 

Checking your identity

 

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

 

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

 

Our Contact Details and Data Protection Lead

Our Data Protection Lead is our Managing Director, Rebekah Heath

 

Our contact details are:

 

Clean Sweep SW Ltd

Exeter Estates

Peamore, Alphington

Exeter, EX2 9SL

 

Reviewing Our Data Protection Policy and Privacy Notices

We regularly review and, where necessary, update our privacy information.

 

If we plan to use personal data for a new purpose, we update our privacy information. If that purpose is not something an individual would reasonably expect we communicate the changes to individuals before starting any new processing.

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