FOX PRIVACY POLICY
We are FOX Manged Solutions Limited, company registration number 10777974, located at 3 Chapman Way, Tunbridge Wells, Kent TN2 3EF.
We maintain the security and performance of our data handling systems and website through controls which are part of our Information Security Management System (ISMS) complying with the requirements of ISO 27001.
We have carried out assessments of the legal basis for processing personal data and have concluded that this is necessary on the grounds of contractual and legal obligations together with our legitimate interests for the use of client and employee data for our commercial interests and employment respectively.
How we use your information
This Privacy Policy tells you what to expect when we collect and process personal information. For professional personal data (e.g. business-related data) the legal basis for this is our legitimate interests, namely the control and maintenance of our website and/or business administration and/or the performance or creation of a contract between you and us. For employment related personal data, the legal basis for this is our legitimate interests, namely the protection and assertion of legal rights and/or the performance or creation of a contract between you and us as an employer and/or employment and fiscal legal obligations.
We will not store any of your information outside of the European Economic Area [EEA]
Should we decide to process any personal data for a purpose other than that for which it was collected, we will provide you with information on that other purpose and with any relevant further information prior to that further processing.
We will not disclose personal data or information about your business, with any third parties or organisations other than our own (FOX and associated companies) without your consent. However, there may be circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics.
Retention
We only retain personal data for as long as necessary to satisfy the following requirements:
Legal: We are required to meet our legal obligations regarding the retention periods for some data, such as financial records and information (7 years for data relating to financial transactions)
Contractual: Your data will be retained for the duration of your contract term, to enable us fulfil our contractual obligations. We may retain this data for a further period of 6 years for marketing and business analysis purposes.
Marketing: Where we hold data for marketing purposes, then it is retained for a period of 18 months of inactivity.
Visitors to our website
When you visit our website, we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website.
In order to provide you with our products and services, or to reply to any enquiries, we collect professional information (e.g. business-related data) about you and your company submitted to our websites, passed on during telephone conversations, included in emails and mobile messaging and any other form of written or verbal communication. For example, we might keep a record of your name, work address and associated delivery addresses, work email address and work telephone number/s.
We also hold the IP addresses of visitors to the website.
By continued use of our website, you consent to the Company collecting analytical and professional information about you and your organisation in accordance with the terms set out in this Policy. You also consent to the Company using the analytical and professional information for market research, marketing, sales, customer relationship management (CRM), operational, financial and legal purposes in accordance with the terms set out in this Policy.
Here at FOX we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us.
Job Applicant Privacy Notice
As part of any recruitment process, the Company collects and processes personal data relating to job applicants. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the Company collect?
The Company collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK.
The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The Company may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The Company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the Company process personal data?
The Company needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, the Company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.
The Company may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
For some roles, the Company is obliged to seek information about criminal convictions and offences. Where the Company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
The Company will not use your data for any purpose other than the recruitment exercise for which you have applied. If your application is unsuccessful, the Company may keep your personal data on file in case there are future employment opportunities for which you may be suited. The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.
The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
The Company will not transfer your data outside the European Economic Area.
How does the Company protect data?
The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for one year after the end of the relevant recruitment process. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
Your rights
As a data subject, you have a number of rights. You can:
access and obtain a copy of your data on request;
require the Company to change incorrect or incomplete data;
require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact HR at [email protected] If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.
Automated decision-making
Recruitment processes are not based solely on automated decision-making.
Services
We offer various products and/or services to our clients. We have to hold the details of the people who have requested the products and/or services in order to provide it. However, we only use these details to provide the product and/or service that have been requested and for other closely related purposes. When you subscribe to our products and/or services, you can cancel this at any time.
Cookies
We may automatically log personal data or link information automatically logged by other means with personal data about specific individuals. However, we will only use this information to help us respond to queries you may have about our products or services or to tell you about other products and services that we think you may be interested in. We will not pass this information on to any third parties.
The Internet browser that you use may make use of a feature called a “cookie” to assign identification to your computer. We do not use cookies to store personal data or to link personal data to non-personal data, unless you have first agreed to this by selecting the “Remember Me” option. If you select this option, a cookie will be placed on your computer which will allow our website to recognise you when you return to our website. No personal information will be stored in this cookie.
We may use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance.
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete our cookies having visited the site.
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
Complaints
When we receive a complaint from a person or company we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any staff members involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
Access to your information and correction
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address. We may make a small charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
How to contact us
Please contact us if you have any questions about our Privacy Policy or information we hold about you:
Write to us: The Information Security Officer, FOX Managed Solutions Limited, 3 Chapman Way, Tunbridge Wells, Kent TN2 3EF.
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