Privacy Policy
Jethro Integrated is committed to being transparent about how it collects and uses the personal data of its external stakeholders, such as clients, suppliers, business partners etc., and to meeting its data protection obligations. This policy applies to the personal data of all stakeholders and sets out the organization's commitment to data protection, and individual rights and obligations in relation to personal data.
Definition
“Personal data” is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it. “Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data. “Criminal records data” means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data Protection Principles
The organization processes personal data in accordance with the following data protection principles:
The organization processes personal data lawfully, fairly and in a transparent manner.
The organization collects personal data only for specified, explicit and legitimate purposes.
The organization processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
The organization keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
The organization keeps personal data only for the period necessary for processing.
The organization adopts appropriate measures to make sure that personal data is secure, and protected against unauthorized or unlawful processing, and accidental loss, destruction or damage.
The organization tells individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. Where the organization relies on its legitimate interests as the basis for processing data, it will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.
Where the organization processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with a policy on special categories of data and criminal records data. The organization will update personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the lifetime of the contractual arrangements with our stakeholders is held on hard copy and electronic format within Jethro Integrated IT systems, such as financial systems and network drives. The periods for which the organization holds personal data are contained in its privacy notices. The organization keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Individual Rights
As a data subject, individuals have a number of rights in relation to their personal data.
Subject Access Requests
Individuals have the right to make a subject access request.
If an individual makes a subject access request, the organization will tell him/her:
whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;
for how long his/her personal data is stored (or how that period is decided); his/her rights to rectification or erasure of data, or to restrict or object to processing; his/her right to complain to the Information Commissioner if he/she thinks the organization has failed to comply with his/her data protection rights;
and whether or not the organization carries out automated decision-making and the logic involved in any such decision-making.
The organization will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise. If the individual wants additional copies, the organization will charge a fee, which will be based on the administrative cost to the organization of providing the additional copies.
To make a subject access request, the individual should send the request to hello@jethrolondon.com The organization has the right to ask for proof of identification before the request can be processed. The individual will need to verify his/her identity and the documents it requires.
The organization will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organization processes large amounts of the individual’s data, it may respond within three months of the date the request is received.
The organization will write to the individual within one month of receiving the original request to tell him/her if this is the case. If a subject access request is manifestly unfounded or excessive, the organization is not obliged to comply with it. Alternatively, the organization can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organization has already responded. If an individual submits a request that is unfounded or excessive, the organization will notify him/her that this is the case and whether or not it will respond to it.
Other Rights
Individuals have a number of other rights in relation to their personal data. They can require the organization to:
rectify inaccurate data;
stop processing or erase data that is no longer necessary for the purposes of processing;
stop processing or erase data if the individual’s interests override the organization's legitimate grounds for processing data (where the organization relies on its legitimate interests as a reason for processing data);
stop processing or erase data if processing is unlawful;
and stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override the organization's legitimate grounds for processing data.
To ask the organization to take any of these steps, the individual should send the request to hello@jethrolondon.com
Data Security
The organization takes the security of personal data seriously. The organization has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. Access to the Jethro Integrated internal IT infrastructure is controlled by password protection and as such has measures in place to minimize risk of illegal access from outside parties. All external third-party systems used by Jethro Integrated are password protected and access is restricted in line with the role of employee. Where the organization engages third parties to process personal data on its behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of data.
Impact Assessments
Some of the processing that the organisation carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, the organisation will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
Data Breaches
If the organisation discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect. If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International Data Transfers
The organisation will not transfer HR-related personal data to countries outside the EEA.
Individual Responsibilities
Individuals are responsible for helping the organization keep their personal data up to date. Individuals should let the organization know if data provided to the organization changes, for example if an individual changes their contact number and or email address.
Jethro Integrated employees may have access to the personal data of Jethro Integrated external Stakeholders in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the organization relies on individuals to help meet its data protection obligations to staff and to all stakeholders.
Individuals who have access to personal data are required:
to access only data that they have authority to access and only for authorized purposes;
not to disclose data except to individuals (whether inside or outside the organization) who have appropriate authorization;
to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
not to remove personal data, or devices containing or that can be used to access personal data, from the organization's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
not to store personal data on local drives or on personal devices that are used for work purposes;
and to report data breaches of which they become aware immediately.
Significant or deliberate breaches of this policy, such as accessing employee, customer, client or supplier data without authorization or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice. The organization will provide awareness training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter. Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.