CooperativeHR Ltd (“We”) are committed to protecting and respecting your privacy.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.cooperativehr.co.uk (our “site”) and/or by using our services you are accepting and consenting to the practices described in this policy.
1. Who we are
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is CooperativeHR Ltd, a company registered in England and Wales with company registration number 10872614 and our registered office is at 25 Newtown Avenue, Bognor Regis, West Sussex, Po21 5HS.
We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters. As controller we are responsible for, and control the processing of, your personal data.
Post: CooperativeHR Ltd, Privacy Enquiries, BizSpace, Courtwick Lane, Littlehampton, West Sussex, BN17 7TL
2. Information we may collect from you
We may collect and process the following data about you: Information you give us. You may give us personal information about yourself by filling in forms on our site or by corresponding with us by
phone, email or otherwise. This includes information you provide when you:
- subscribe to any other service we offer through our site;
- participate in discussion boards or other social media functions on or linked to our site
- enter a competition, promotion or survey;
- request a sample report or complete a form in order to download content;
- when you raise a complaint or report a problem;
The information you give us may include your name, job title, profession, address, email address and phone number, personal description, demographic information such as post code, preferences and interests.
Information we collect about you
With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plugin types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page.
- web browser type and version (automatically collected);
- operating system (automatically collected); and
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected)
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we hereby inform you that when we collect that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, subcontractors in technical services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We may screen record your ‘session’ using a third-party service for the purposes of improvement and optimisation of the services we provide and for the purposes set out in paragraph below. This recording will show all browser window activity including keystrokes and mouse movements relating to our URLs only, no other browser window will be recorded.
We do not knowingly collect “special category” personal data, except as part of our employment process. This is a special type of sensitive data to which more stringent processing conditions apply:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership
- genetic and biometric data.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to ensure that we maintain our commitment to equality of opportunity for all job applicants whilst ensuring we comply with our legal obligations in relation to recruiting into specific roles.
We rely on the lawful basis of legal obligation to process this data.
3. How we use the information
We use information held about you in the following ways: Information you give to us
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to provide you with information about other services we offer that are similar to those that you have already applied for, attended or enquired about;
- to notify you about changes to our services;
- to ensure that content from our site is presented in the most effective manner for you and for your computer or device;
Information we collect about you
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Lawful processing
In order to process personal data, we must have a lawful reason. We always ensure that this is the case, and we set out our lawful bases below (note that more than one may apply at any given time).
We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.
If you are our customer, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our products and services to you:
- to enable us to carry out our services
- to identify you
- to respond to your inquiries
- to the extent necessary to provide you with information you have requested in relation to our products and services before you decide to purchase them
- to provide our products and services, including enabling them to be provisioned or delivered to you and contacting you about your order
- to carry out billing and administration activities, including refunds and credits
Of course, you are not obliged to provide us with any of this information, but if you chose not to, we may be unable to provide the product or service that you have requested.
We process your personal information for our legitimate business purposes or if you are applying for a job, which includes the following:
- to conduct and manage our business
- to ensure our website and systems are secure
- to personalise your web experience
- to analyse, improve and update our services for the benefit of our customers
- to deal with complaints
- where you have made a purchase from us, to let you know about our products, services, promotions or events that we consider may be of interest to you (and which may be tailored to your interests as construed from your purchase history). We do this only where you have provided us with a preferred means of contact for this purpose. We carry out this processing on the legal basis that we have a legitimate interest in marketing our products and services, and only to the extent that we are permitted to do so by applicable direct marketing laws. You can opt out of receiving this information by unsubscribing from our emails, or by contacting us as set out in Section 1 above.
- to evaluate your job application and take any next steps, and to evaluate your suitability for roles where you have asked to be considered for future opportunities.
Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.
Compliance with laws
We may process your personal data in order to comply with applicable laws (for example, if we are required to co- operate with an investigation pursuant to a court order).
If you have never purchased from us or have not purchased from us after a long period of time but have given us your explicit consent to hear from us about our products, services, promotions or events that we consider may be of interest to you, we will contact you by email. You have the right to withdraw consent to marketing at any time.
5. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as applicable and as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
- We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site. We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to
- the prospective seller or buyer of such business or assets.
- If CooperativeHR Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6. Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to agree to or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting using the details in section 1.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We draw your attention to your following rights under data protection law:
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you.
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to
- be subject to automated decision making in way that adversely affects your legal rights.
- You have a right not to be subject to automated decision making in any way that adversely affects your legal rights.
- Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Please contact us using the details in section 1 of this notice if you would like to exercise any of these rights or know more about them.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.
7. Where we store your personal information and for how long
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this policy or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.
9 Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
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.