GDPR transparency notice for suppliers, customers and contractors
TSR Leadership (“we” or “us”) is the trading name of Transform and Sustain Results Limited, company number 10514278 and registered office at 18 Wheatley Road, Ilkley, West Yorkshire LS29 8TS, UK.
What is the purpose of this document?
This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during our relationship with you and after it ends. We are required to notify you of this information under data protection legislation.
We will comply with the data protection principles when gathering and using personal information. It is therefore important that you read this notice (sometimes referred to as a ‘Transparency Notice’), together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information.
We are a ‘data controller’ and gather and use certain information about you. This information is also used by our affiliated entities and group companies, and so, in this notice, references to ‘we’ or ‘us’ includes all TSR Leadership group companies.
This notice applies to all people liaising with us, including suppliers, customers, fixed and full-time contractors, as well as people who have supplied their details to us not in relation to a specific assignment. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for assignments with customers (“Customers”) as part of a managed service provider programme or recruitment processing outsourcing service offering or otherwise will be treated as contractors for the purposes of this Transparency Notice (hereinafter referred to collectively as “Contractors”).
Whilst the reference to Customers in this Transparency Notice is, in itself self-explanatory, this category covers our customers, clients and others to whom TSR Leadership provides services in the course of its business.
What personal information are we collecting?
Personal data, or personal information, means any information relating to an identified of identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymous data).
There are special categories of more sensitive personal data which require a higher level of protection, please see later for more information.
For Customer we will collect, store and use the following categories of personal information about you:
your name, title, addresses, telephone numbers, and personal email addresses;
age/date of birth;
next of kin and emergency contact information;
financial information (where we need to carry out financial background checks);
information on your interests and needs regarding future assignments, both collected directly and inferred, for example from correspondence or articles read on our website;
extra information that you choose to tell us;
extra information that we may find from other third-party sources;
For Contractors we will collect, store and use the following categories of personal information about you as per Customers, plus:
your references and other information included in a CV or cover letter or as part of the application process (including psychometric test scoring and results);
your work history and employment records (including job titles, working hours, training records and professional memberships);
feedback from Customers on your performance;
extra information that your referees choose to tell us about you; and
extra information that our Customers may tell us about you.
Particularly sensitive personal information
We process special categories of personal information in the following circumstances:
We process information about you relating to criminal convictions for the purpose of carrying out a DBS check. We only do this where required by law or where this is a condition of contract imposed by a Customer for the assignment we are liaising over. We will contact you prior to carrying out such checks. If there is no legal obligation to undertake these checks we only do so with your consent.
If you voluntarily provide us with special category information we may share this with our Customer. Our lawful basis for processing in this case is that you have voluntarily made the information public.
Less commonly, we may process special category information where it is needed to protect your vital interests (or someone else's interests) and you are not capable of giving your consent, or where it is in the substantial public interest.
Otherwise we will only process special category information with your consent.
How will we collect your personal information?
We will collect personal information from you directly when you register with us or contact us about our services or when we make contact with you. This may be by telephone or email.
We will collect information throughout our sales process, either directly from you or from third-party referrals.
We will sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
We will collect information from publicly available sources including social media sites such as LinkedIn.
For contractors, we will collect feedback from our Customers on your performance during the course of your assignment.
We may from time to time collect information automatically.
For what purpose will we use your personal information?
When you liaise with us, we will use your personal information to perform our contract with you, or to take steps prior to entering into this contract, with you. To do this, we will process your personal information in the following situations:
to provide our services to you. Our services consist of management consultancy; and
to contact you about improvements that we think you may be interested in and to keep in touch with you; and
to manage our relationship with you.
We will also use your personal information to:
verify information about you which we may do using publically available sources;
monitor your use of our information and communication systems to ensure compliance with our IT policies;
ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and
conducting data analytics studies to review and better understand employee retention and attrition rates.
the above processing is necessary for the legitimate interests of the smooth running of our business, and to enable us to provide services to you.
What are the legal bases for us to use your personal information?
We will only use your personal information when the law allows us to do so. 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; and
where it is necessary for our legitimate interests (or those of a third party) to ensure the smooth running of our business as a recruitment agency. We are allowed to do this as long as our activities do not disproportionately intrude your privacy. Where we rely on legitimate interests as the lawful basis for processing, the relevant interest is set out in this notice.
We will also use your personal information in the following situations, which are likely to be rare:
where we need to protect your interests or someone else's interests;
it is necessary in the public interest; or
otherwise with your consent.
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 providing you a benefit).
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, where this is required or permitted by law.
Although at present all our activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a relevant processes from end-to-end, where appropriate and in accordance with any local laws and requirements.
Where appropriate, we will seek your consent to carry out some or all of these activities.
Who are we going to share your personal data with and for what purpose will they use your personal information?
We will share your personal information with the following third parties and they will process personal information about you for their own purpose:
potential Customers to find you, our Contractor, a suitable assignment;
the Customer that we place you with to manage our relationship and to make payment of invoices;
individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws (in the applicable country).
We may share the results of our diversity and inclusion monitoring on an anonymised basis.
We may share your data with third-party service providers (including contractors and designated agents), and other businesses that provide certain services on our behalf. The following activities may be carried out by third-party service providers: IT support, mailing services, payroll; and website hosting.
We may also share your data with other third-party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems).
We may share your data with tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation).
All of our third-party service providers and other entities in the TSR Leadership 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.
Where will we store your personal information?
We will store your information on our central database which is held on secure cloud based servers contracted with a UK service provider. Information on our database may be accessed internally from anywhere globally .
If you require further information these protective measures you can request it from email@example.com
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
How long will we use your personal information for?
We will only keep your personal information 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.
We will retain your personal information for a number of purposes, as necessary to allow us to carry out our business. Your information will be kept for up to 3 years from the last point of contact on our main systems after which time it will be anonymised, archived or deleted.
Some of the archived information may be retained for up to 7 years for the purposes of satisfying any legal, accounting, or reporting requirements (or equivalent in your country such statutory requirement, plus 1 year). Any retention of personal data will be done in compliance with legal or regulatory obligations and with industry standards. These data retention periods are subject to change without further notice as a result of changes to associated law or regulations.
If you have any questions in relation to the retention of your personal data, please contact firstname.lastname@example.org
Your rights in relation to our processing of your personal data
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if any of your personal information changes during your relationship with us.
Your rights in connection with personal information
You have the right to be informed about what we are doing with your personal data. This notice sets out how we use it. If we change what we are doing we will provide you with an updated version of this notice.
You have the right to object to the processing of your personal data.
You have the right to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
You have the right to request us to update the personal information we hold about you.
You have the right to request us to delete the information we hold about you. If you ask us to delete your personal information we will not be able to provide our services to you.
You have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
You have the right to ask us to restrict how we use your personal data for a period of time. If you ask us to restrict our use of your personal data, we may not be able to provide you with our services.
You have the right to request us to send another organisation, information that you have provided to us in a format that can be read by computer.
If you want to exercise your rights please contact email@example.com
We will 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).
Changes to this transparency notice
We reserve the right to update this transparency notice at any time, and we will provide you with a new transparency 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.
If you have any questions about this transparency notice, please contact firstname.lastname@example.org
If you consider that we have not acted properly when using your personal information, you can contact the Information Commissioner's Office: ico.org.uk.
Name of company Transform & Sustain Results Ltd.
Registered office 18 Wheatley Road, Ilkley, West Yorkshire, LS29 8TS
Tel: +44 745 6291347 +44 745 6291347
VAT no. 257 4977 52