Privacy Notice

Watts of Lydney Group Limited is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

Watts of Lydney Group Limited is a “data controller”. This means that we are required under data protection legislation to notify you of the information contained in this privacy notice.

You should read this notice so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The personal data we collect will depend on the relationship we have we have with you and why we interact with you or the organisation that you represent.

We may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and email ad- dresses.
Gender.
Name and address of employer and location of employment or workplace.
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, training records and pro- fessional memberships).
Information about your online presence such as Linkedin profile and twitter identity.
Photographs, driving licence details and insurance documents

How is your personal information collected?

We collect personal information from you directly. We may sometimes collect additional information from publicly available resources (e.g. Companies House, H M Land Registry etc), third parties in- cluding former employers, credit reference agencies, through our website, and via our email and IT systems.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
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.
Where you have given consent.

Situations in which we will use your personal information

We need all the categories of information that we collect primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your person- al information to pursue legitimate interests of our own or those of third parties, provided your inter- ests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

Administering the contract we have entered into with you.
Business management and planning, including accounting and auditing.
Making decisions about engagement as a customer or supplier for example – this may involve credit checks and reference checks.
Education, training and development requirements.
Dealing with legal disputes involving you.
Complying with health and safety obligations.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribu- tion.
To conduct business data analysis to review and deliver the best products and service to you in the most cost effective way.
To ensure confidentiality of commercially sensitive information.
Marketing our services to existing and former customers, third parties who have expressed an interest in our products or services whether or not they have previously dealt with us.

Some of the above grounds for processing will overlap and there may be several grounds which jus- tify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a product or service), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our or your workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Promotional Communications Including Newsletters

We may use your personal data to send you updates by email, text message, telephone or post:

About new developments in our business or industry that may be of interest to you.
We have a legitimate interest in processing your personal data for promotional and marketing purposes and this means we do not normally need your consent to do this.
If we do need your consent then we will ask for this consent clearly and separately.
We will always treat your personal data with respect and never sell or share it with other organi- sations outside the Watts of Lydney Group for marketing purposes. .
You have the right to opt out of receiving promotional communications at any time by contacting us by email to gdpr@watts-group.co.uk. or using the unsubscribe link in emails or STOP in texts.

Data sharing

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is neces- sary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third parties may we share information with?

credit reference agencies
our Group companies
our insurers and brokers
our auditors
our banks
external service providers that we may use to make our business more efficient – for ex- ample agencies, document processors, analysis suppliers.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transferring information outside the EU

[We will transfer the personal information we collect about you to the following [country OR coun- tries] outside the EU [LIST] in order to perform our contract with you. There [is OR is not] an ade- quacy decision by the European Commission in respect of [that OR those] [country OR countries]. This means that the [country OR countries] to which we transfer your data are [deemed OR not deemed] to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: [SPECIFY MEASURE, FOR EXAMPLE, BINDING CORPORATE RULES]. If you require further information about [this OR these] protective measure[s], [you can request it from [POSITION] OR it is available [ON THE INTRANET/PROVIDE LINK HERE].]

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from be- ing accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we col- lected 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

When it is no longer necessary to keep your data we will destroy it.

Transferring Data Outside the EEA

To deliver services to you it may be necessary to share your personal data outside the European Economic Area, e.g..

when you are located outside the EEA
when there is an international dimension to our business with you
if we use a sub contractor or agent based outside the EEA

These transfers are subject to special rules under European and UK data protection law. We will ensure that any such transfer complies with GDPR and all data is secure. We use data transfer clauses that have been approved by the European Commission.

Rights of access, correction, erasure, and restriction

You have the following rights that are available free of charge.

Request access to your personal information (commonly known as a “data subject access re- quest”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exer- cised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact gdpr@watts-group.co.uk.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data protection officer

You may contact our GDPR team on gdpr@watts-group.co.uk at any time. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.