We are committed to protecting and respecting your privacy and this privacy notice provides you with details of how we collect and process your personal data through your use of our site www.smehrservices.co.uk (including any information you may provide through our site when you contact us) and our wider services.
Who we are
We are Emma Lister t/a SME HR Services.
Contact address: firstname.lastname@example.org
We are registered with the Information Commissioner’s Office, registration reference A8280375.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
We keep this privacy notice under regular review and may update this policy notice from time to time without prior notice to you. We will post a prominent notice on our webpage to notify you of any significant changes.
Paper copies of this privacy notice are available on request. Please contact us at firstname.lastname@example.org.
Glossary of Terms
What is personal data?
“Personal data” relates to any information about a natural person that makes them identifiable. It does not include anonymised data.
What is sensitive personal data?
Sensitive personal data or “special categories of personal data” refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
Personal data relating to criminal convictions and offences are not included, but similar extra safeguards apply to its processing.
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
“Data processing” is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What data do we collect about you?
The personal information we collect from you will vary depending on which products and/or services you engage us to deliver.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your Unique Tax Reference Number (UTR), your National Insurance number, bank account details.
- Transaction Data may include details about payments between us.
- Technical Data may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Usage Data may include information about how you use our website, products and services.
- Communications Data may include your communication preferences.
- Employee Data we may also collect data relating to your employees (including their identity data, contact data, financial data and other HR related data relating to their employment with you).
We may also process aggregated data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the aggregated data with your personal data so that you can be identified from it, then it is treated as personal data.
We may need to collect sensitive data and data relating to criminal convictions and offences relating to your employees for the purposes of providing you with HR and employment law advice.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.
How we collect your personal data
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) (i.e. by sending an email enquiry) or by communicating with us by post, phone, email or otherwise, including when you request our products or services; subscribe to our service or publications; request resources be sent to you; or give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from our service providers who provide IT/Website and System administration services and analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly availably sources such as Companies House, the Electoral Register etc.
How we use your personal data and why
We will only use your personal data to enable us to supply the services and/or products you have engaged us to deliver and for other purposes including; where we need to contact you by post, email or telephone; where we need to update and enhance our existing client information/records in accordance with applicable legal and regulatory obligations; for analysis for management purposes; where we need to verify your identity; for purposes of processing financial transactions; for purposes of legal and regulatory compliance; to prevent and detect crime, fraud and corruption; and 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.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- To enable us to take steps at your request to enter into a contract with you;
- To provide and manage the performance of our contract with you;
- To manage our relationship with you and maintain a record of that relationship;
- To comply with our legal and statutory obligations;
- To provide and manage access to our site;
- To communicate with you, by email, telephone and post;
- To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support reporting and hosting of data;
- To analyse your use of our site to enable us to continually improve our site.
Disclosures of your personal data
We may have to share your personal data with our third party service providers, agents and subcontractors and other associated organisations for the purposes of providing our products and/or services to you. This will include but is not limited to:
- Service providers who provide us with IT and System Administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
- HM Revenue & Customs, Companies House, Regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
- Third parties to whom we sell, transfer, or merge parts of our business or our assets
When we use third party service providers, we disclose only the personal information that is necessary to deliver to you the products and/or services that you have requested from us. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. We have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers may be located outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data. Where we transfer your personal data to countries where there is no adequacy decision by the European Commission in respect of that country, we will put in place certain measures to ensure that your personal data does receive an adequate level of protection, such as contractual clauses that have been approved by the European Commission. Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Data security is very important to us and we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a series of internal policies and controls designed to minimise the risk to your data.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Please note, the transmission of information via the internet is not completely secure. Although we do our best to try and protect your information, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data 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.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being a client for tax purposes.
Typically for contracted services we will hold your data for a period of at least 6 years from the end of contract with you or such longer period as may be required to reflect the Statute of Limitations. After which it will be destroyed in a safe way.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Access to your information: You have the right to request a copy of the personal information about you that we hold.
Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information: You have the right to ask us to delete personal information about you where:
- you consider that we no longer require the information for the purposes for which it was obtained
- you have validly objected to our use of your personal information – see ‘Objecting to how we may use your information’ below
- our use of your personal information is contrary to law or our other legal obligations
Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue. You have the right at any time to require us to stop using your personal information for direct marketing purposes.
Withdrawing consent to use your information: Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We seek to resolve directly all complaints about how we handle your personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office at:
Information Commissioner’s Office
Telephone – 0303 123 1113 (local rate) or 01625 545 745