Bar2 is a data controller for the purposes of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). We are responsible for ensuring that any processing of your personal information by us is done fairly and lawfully. Processing your personal data includes holding, obtaining, recording, using or sharing it. We take your privacy very seriously and will only process your personal data for the purposes set out in this notice.
The person responsible for data protection enquiries is Joss Lowery who can be contacted on Tel: 01923 690910 /email joss.lowery@bar2.co.uk.
Details about the purposes for which your personal data may be processed and the basis processing your personal data, together with details of your rights in relation to the processing of your data can be found at www.bar2.co.uk.
The purposes for which your personal data will be processed
We will need to process your personal data for the purposes of providing payroll services and related services to our clients.
The lawful basis for processing your personal data
The legal bases upon which we may rely to process your personal data are:
- Contractual obligation
- Legal obligation
- Legitimate interest
- Consent
In certain circumstances we are required to process certain categories of personal data in order to comply with our legal obligations under relevant legislation, including HMRC, tax, social security or other legislation. You are not under any obligation to provide us with your personal data, but if you do not, we may be unable to meet our legal obligations and so may not be able to provide you with our payroll services.
We also need to process certain categories of your personal data in order to enter into an agreement with you and to comply with our obligations under that agreement.
Where no contractual or legal obligation exists, we may still need to process your personal data in order to pursue our legitimate business interests. Our business involves providing payroll services and related services to our clients and so we may need to process your personal data in order to pursue our legitimate interests in achieving this. We may also need to retain personal data in case we need to establish or defend a legal claim. We will balance our legitimate interests against your rights and legitimate interests and expectations.
We may rely on your consent in certain circumstances, for example to process your data for the purposes of sending you direct marketing by email or text message, to use cookies when you visit our website, or to process sensitive personal data.
The bases upon which we may lawfully process your personal data are listed in the table below.
|
Document / Personal Data |
Why we need it |
Our lawful ground for processing it |
|
Name, address, DOB |
To verify your identity |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
Contact details |
To communicate with you regarding our payroll services and other important information |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
Payment requirements |
To find you the right payroll solution for you |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
ID and immigration checks |
To verify your identity and right to work |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
Notes, comments, from telephone calls. |
To find you the right payroll solution for you |
Contractual obligation (if applicable). Legitimate interests. |
|
Emails and correspondence with you intermediaries |
To find you the right payroll solution for you |
Contractual obligation (if applicable). Legitimate interests. |
|
Details of placement/assignment and hirer |
To keep records of placements made by your recruitment agency |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
Bank details |
To pay you |
Legal obligation (If applicable) Contractual performance. |
|
Social security information, NI number |
To report to HMRC |
Legal obligation (If applicable) Contractual performance. |
|
Information about your pay and conditions |
To protect your rights |
Legal obligation (if applicable). Contractual obligation (if applicable). Legitimate interests. |
|
Other necessary, relevant personal information |
To perform our services for you |
Contractual obligation (if applicable). Legitimate interests. |
|
IP address, browser and device data |
To deliver relevant website content and administer our website |
Legitimate interests. |
Direct Marketing
We would like to use your contact details to contact you about news and information which we think may be of interest to you. However we will not contact you with marketing material unless you consent to our doing so, and you have the right to unsubscribe at any time, by clicking the link which appears in the email footers of marketing emails.
Sensitive personal data
Sensitive personal data includes information about your health, criminal convictions and allegations, sex life and orientation, racial origin, ethnic origin, religious views, political opinions and /or any trade union membership. We may need to process certain categories of sensitive personal data about you for the following purposes:
- Eligibility to work data such as passport and visa checks
- Bank, tax and social security data such as account numbers, NI number, Unique Tax Reference (UTR)
We acknowledge the sensitivity of this type of data and will normally only ever process it with your express consent, unless the processing of your sensitive personal data is necessary for other reasons permitted by law. Please do not disclose any sensitive personal data about yourself to us unless we request it or it is essential to do so. Unsolicited personal data will be deleted.
Sharing your personal data
Your personal information will be processed by our staff and our subcontractors (including IT providers) and will be provided to appropriate third parties such as potential hirers and intermediaries in order to provide you with payroll services. Please let us know if you do not want your personal information to be disclosed to a particular third party or category of third parties.
We may be required by law to share certain categories of your personal data with tax authorities and other government agencies including HMRC and the Home Office.
We may use a third party organisation to operate our ‘right to work’ checks where applicable.. We will need to provide them with certain categories of your personal data and they will be under an obligation to process it as instructed by us and in accordance with relevant data protection legislation. We may also need to provide certain categories of personal data to your pension provider, if appropriate.
We will not share your personal data with any other organisation unless it is necessary and in connection with providing our payroll services.
Overseas transfers
Data will be stored within the EEA on either local or cloud-based servers and will be subject to technical and organisation safeguarding protection measures. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Some categories of data may be transferred outside the EEA. If it is necessary to transfer your data to a country outside the EEA to assist us in providing work-finding and recruitment services, we will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to technical and organisation safeguarding protection measures.
Accuracy of your data
We will endeavour to keep your personal data accurate and up to date and will only process it for the specific purposes notified above. Data that is inaccurate or out of date will be deleted. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal data, we hold about you.
Retaining your data
Different laws require us to keep different data for different periods of time.
We must keep payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as legally required by tax authorities and relevant social security and tax legislation.
We may also retain your personal data in order to pursue our legitimate business interests. We will not store your data for any longer than is necessary to comply with our legal obligations or to pursue our legitimate business interests. We will delete your data in line with our retention policy which is can be found at www.bar2.co.uk.
Your rights
Whilst we are processing your data, you have the right to:
- request access personal data we hold about you;
- object to the processing of your personal data;
- ask to have inaccurate data held about you removed;
- ask to have inaccurate data held about you or corrected;
- if processing of your personal data is based only on consent, to withdraw that consent;
- request that your personal data is shared with a third party.
Data security
We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.
We will only transfer personal data to a third party if they agree to comply with those procedures and policies or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
Further information and breach reporting
If you require any information about the way in which we process your data or if you wish to report a complaint or a data breach, please contact Joss Lowry on Tel: 01923 690910 /email: joss.lowery@bar2.co.uk as soon as possible. All enquiries will be responded to as quickly as possible and all data breaches will be taken very seriously. If for any reason you are dissatisfied with the way in which your personal data has been processed, you can complain to the appropriate supervisory authority for data protection:
Information Commissioner’s Office (ICO)
Head office: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Scotland office: 45 Melville Street, Edinburgh EH3 7HL
Wales office: 2nd floor, Churchill House, Churchill way, Cardiff CF10 2HH
Northern Ireland office: 3rd Floor, 14 Cromac Place, Belfast BT7 2JB
Phone Number: 0303 123 1113 or
Website: https://ico.org.uk/concerns/.