PRIVACY NOTICE – Version 2, 21 May 2018
Smart HR Solutions Limited is a company incorporated and validly existing under the laws of the Isle of Man with company number 124794C. We are committed to protecting your privacy when visiting our website or using our services.
This Privacy Notice (the ‘Notice’) explains how we use any personal information we collect about you when you use this website or when you contact us directly. The Notice sets out how we, from time to time, process the personal data of individuals who contact us or who use our website, services, applications, content and related features (collectively, the ‘Website’).
This Notice sets out our views and practices in respect of your personal data and how we will treat it. Please read this carefully. By visiting our Website, you acknowledge the processing described in this Notice.
From time to time we may make changes to this Notice by posting on our Website or otherwise. Your continued use of the Website, our services or your continued dealing with us after notification of such changes will amount to your acknowledgement of the amended Notice.
HOW TO CONTACT US
Please contact us if you have any questions about this Privacy Notice or information we hold about you by writing to us at the following address:
FAO: Data Protection Officer, Smart HR Solutions Limited, 6 Hilltop Rise, Farmhill, Douglas, Isle of Man, IM2 2LF.
Alternatively, you can email us at contact@SmartHR.co.im
WHAT IS PERSONAL DATA?
‘Personal data’ means any information relating to an identified or identifiable natural person, known as a ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, a recording of your call with us and similar information. It may also include ‘special categories of personal data’ such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sex life or sexual orientation.
WHAT PERSONAL DATA TO WE PROCESS?
We may process the following personal data:
Information provided by you. You may give us information about you by, for example, filling in forms such as the contact form on our Website, subscribing to services such as email updates, making applications in respect of job postings, corresponding with us by email, phone or otherwise. This information may include your name, email address, phone number, information about your query and similar information. We may also receive a copy of your CV or a similar document in respect of a job vacancy or a speculative job enquiry. When you purchase materials/documents and/or services from our website (or if you purchase materials/documents and/or services directly from Smart HR Solutions Limited using a card payment), the payment will be processed using a third-party payment processor, acting on behalf of Smart HR Solutions Limited, on a secure website and they will obtain and verify the payment card details that you supply. Smart HR Solutions Limited will endeavour to ensure any third party acting on behalf of Smart HR Solutions Limited uses encryption to ensure payment data is protected.
Information about others. You may also provide to us personal data relating to third parties, such as people who you work with, or your referees. Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.
Information about your device. With regard to each visit to our website we may collect technical information about your device such as IP address, operating system, browser, time zone setting, the Internet address of the website from which you linked directly to our website, URL clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Website content and services.
We will rely on the information provided by you as being accurate, complete and up-to-date and you agree to ensure that this will be the case.
HOW DO WE USE YOUR PERSONAL DATA?
We will only process personal data, in accordance with applicable law, for the following purposes:
The legal basis for our processing of personal data for the purposes described above will typically include:
CONTACTING US VIA SOCIAL MEDIA
Smart HR Solutions Limited’s social media message boxes are accessed by restricted personnel who have responsibility for maintaining our social media platforms; this may include a third-party service provider.
We use the following cookies on our Website:
We may combine information from these types of cookies and technologies with information about you from other sources.
Cookie consent and opting out. By using our Website, we assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies; however, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Website and related services.
If you are based in Europe, when you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit. If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings.
DISCLOSURE OF PERSONAL DATA
There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:
We may transfer your personal data to a third-party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred outside of the EU/EEA. Where this is the case, we will ensure that appropriate transfer mechanisms as set in the General Data Protection Regulations (‘GDPR’) are in place to ensure an adequate level of data protection.
If we transfer personal data to private organisations outside of the EU/EEA, such as our suppliers and service providers, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Where this is necessary you may contact us for a copy of such safeguards at contact@SmartHR.co.im.
RETENTION OF PERSONAL DATA
We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law. Further details of applicable retention periods can be provided by contacting us at contact@SmartHR.co.im.
We may keep an anonymised form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
SECURITY OF PERSONAL DATA
We will use appropriate technical and organisational information security measures to try to ensure prevention of any unauthorised access to your personal data; however, transmission of information via the internet is never completely secure. Whilst we will do our best to keep our own systems secure, we cannot control the entirety of the internet and cannot therefore guarantee the security of your information as it is transmitted to and from our Website.
Smart HR Solutions Limited recommends that you install your own security measures, firewalls, software spyware and other appropriate security procedures. We are unable to provide any guarantee that information and data provided to users will be free of viruses or other conditions which may damage or interfere with data, hardware or software with which it might be used. All information sent by Smart HR Solutions Limited is done so on the strict condition that the user carries out and relies upon its own procedures for ensuring that its use will not interfere with the recipient’s systems and the recipient assumes all risk of use and absolves Smart HR Solutions Limited of all responsibility for any consequences of its use.
DATA SUBJECT RIGHTS
Depending on your country’s laws and the legal basis for collection of your data, you may have certain rights in relation to your personal data. Further information about your data privacy rights may be obtained by visiting the website of your local data privacy authority. In summary GDPR provides, as follows:
THIRD PARTY LINKS
“I recently attended the “Developing a High-Performance Culture” seminar given by Emma Walker of SmartHR. The session was thought provoking, informative and enjoyable. In a relatively short period of time Emma was able to cover a broad subject, give us the opportunity to share our collective experiences and learn about some of the leading HR perspectives. I will be looking out for more presentations and workshops led by Emma and SmartHR.”Neal Kelly – Operations Director, PDMS Ltd – Nov 2018
“Dear Gail, Jo and I wanted to thank you for delivering Equality training to our Recruitment Consultants and Administration Team this morning. Feedback was great, they found the content and delivery spot on – targeted, effective and full of practical applications and examples. It’s so valuable in terms of time and impact to have design and delivery of training tailored specifically to the needs of our industry, business and teams. Much appreciated, and we’ll certainly recommend to any of our clients seeking similar support.”Debbie Scrimshaw – Director, Paragon (HR & Recruitment) Ltd – Oct 2018
“In transitioning from being part of a large FTSE250 Company with all the support of the Group Functions to being a standalone entity, we engaged with SmartHR to help us establish all our new HR policies and procedures, including a new Staff Manual and staff contracts. Doing so has proved to be one of the best decisions we made: what at first seemed a mountain to climb was quickly and efficiently dealt with by Gail whose engaging manner and deep knowledge of her subject allowed her to quickly assess our existing group policies and tailor them to meet our new needs with the minimum of fuss. Since then she has also proved to be an invaluable confidante and adviser on HR matters across the board and I have no hesitation in thoroughly recommending her and her company.”John Tottenham – Managing Director, Zeffyr Services Limited – Sept 2018
“SmartHR provided a thorough, professional, first class service to the Gambling Supervision Commission. Gail and Julia were super to work with, understood our issues, provided options and made recommendations that are now starting to bear fruit. The Commission continues to use SmartHR for advice and support in the on-going development of its HR practices and I would have no hesitation in recommending Gail and her team to any organisation.”Steve Brennan – Chief Executive, Gambling Supervision Commission – Sept 2018
“Nedgroup Investments engages SmartHR to provide advice and guidance on a wide variety of human resources related matters. The current changes and updates to employment law affect all employers and it is vital that we adhere to best practice at all times. Gail provides a knowledgeable and efficient service and with her guidance we can be sure that our HR procedures and processes align with the highest industry standards. Working with Gail at SmartHR is a highly cost effective method of engaging a professional HR resource and her patient expertise is always only a phone call away.”Tracey Wiltcher – Director, Nedgroup Investments – Sept 2018