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Data Protection

Hunter Dunning Ltd processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is ZB270598.

The Company may hold personal data on individuals for the following purposes:

  • Staff administration;
  • Advertising, marketing and public relations
  • Accounts and records;
  • Administration and processing of work-seekers personal data for the purposes of providing work-finding services, including processing using software solution providers and back-office support
  • Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers.

The data protection principles

The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:

  1. Processed lawfully, fairly and in a transparent manner;
  2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
  5. Kept for no longer than is necessary for the purposes for which the personal data is processed;
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
  7. The data controller shall be responsible for, and be able to demonstrate, compliance with the data protection principles.

1. Legal bases for processing

Hunter Dunning Ltd will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.
The Company will review the personal data it holds on a regular basis, to ensure it is being lawfully processed and it is accurate, relevant and up to date.

Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back-office support)), the Company will establish that it has a lawful reason for making the transfer.

2. Privacy by design and by default

Hunter Dunning Ltd has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:

  • data minimisation (i.e. not keeping data for longer than is necessary);
  • cyber security

Hunter Dunning Ltd shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual.

1. Privacy notices

Where Hunter Dunning Ltd collects personal data from the individual, it will give the individual a privacy notice at the time when it first obtains the personal data.
Where Hunter Dunning Ltd collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, or at the time it contacts the individual, but at the latest within one month. If the Company intends to disclose the personal data to a third party, then the privacy notice will be issued when the personal data are first disclosed.
Where Hunter Dunning Ltd intends to further process the personal data for a purpose other than that for which the data was initially collected, it will give the individual information on that other purpose and any relevant further information before it does the further processing.

2. Subject access requests

The individual is entitled to access their personal data on request from the data controller.

3. Rectification

At the individual’s request, the individual or another data controller has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.
If the Company has given the personal data to any third parties, it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. If asked to, the Company must also inform the individual about these recipients. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

4. Erasure

The individual or another data controller at the individual’s request has the right to ask the Company to erase an individual’s personal data.
If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.

If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. If asked to, the Company must also inform the individual about these recipients. Those third parties should also rectify the personal data they hold – however, the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

5. Restriction of processing

The individual or a data controller at the individual’s request has the right to ask Hunter Dunning Ltd to restrict its processing of his or her personal data where:

  • The individual challenges the accuracy of the personal data;
  • The processing is unlawful, and the individual opposes its erasure but requests restriction instead;
  • Hunter Dunning Ltd no longer needs the personal data for the purposes of processing, but the individual needs the Company to keep the personal data in order to establish, exercise or defend a legal claim; or
  • The individual has objected to processing (on the grounds of public interest or legitimate interest) pending the verification of whether the legitimate grounds of Hunter Dunning Ltd override those of the individual.

If Hunter Dunning Ltd has given the personal data to any third parties, it will tell those third parties that it has received a request to restrict the personal data unless this proves impossible or involves a disproportionate effort. Hunter Dunning Ltd must also inform the individual about these recipients if asked to. Those third parties should also rectify the personal data they hold – however, Hunter Dunning Ltd will not be in a position to audit those third parties to ensure that the rectification has occurred.

6. Data portability

The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:

  • The processing is based on the individual’s consent or a contract; and
  • The processing is carried out by automated means (i.e. excluding paper files).

Where feasible, Hunter Dunning Ltd will send the personal data to a named third party at the individual’s request.

7. Object to processing

The individual has the right to object to their personal data being processed based on a public interest, the exercise of official authority vested in you, or a legitimate interest (or those of a third party).
The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
The individual has the absolute right to object to the processing of their personal data for direct marketing.

8. Enforcement of rights

All requests regarding individual rights should be sent to the person whose details are listed in page 12.
The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision-making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests. The Company will let the individual know within one month of receiving his or her request and explain why the extension is necessary.
Where Hunter Dunning Ltd considers that a request under this section is manifestly unfounded, or excessive due to the request’s repetitive nature, Hunter Dunning Ltd may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.

9. Automated decision making

Hunter Dunning Ltd will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

  • Is necessary for the entering into or performance of a contract between the data controller and the individual;
  • Is authorised by law; or
  • The individual has given explicit consent.

Hunter Dunning Ltd will not carry out any automated decision-making or profiling using the personal data of a child.

Reporting personal data breaches

All data breaches should be referred to the persons whose details are listed in page 12.

1. Personal data breaches where the Company is the data controller:

Where the Hunter Dunning Ltd establishes that a personal data breach has taken place, Hunter Dunning Ltd will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual Hunter Dunning Ltd will notify the ICO, and where necessary, the individual/s concerned.
Where the personal data breach happens outside the UK, Hunter Dunning Ltd shall alert the relevant authority for data breaches in the affected jurisdiction.

2. Personal data breaches where the Company is the data processor:

Hunter Dunning Ltd will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.

3. Communicating personal data breaches to individuals

Where Hunter Dunning Ltd has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.

All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:

  • Right to respect for private and family life (Article 8).
  • Freedom of thought, belief and religion (Article 9).
  • Freedom of expression (Article 10).
  • Freedom of assembly and association (Article 11).
  • Protection from discrimination in respect of rights and freedoms under the HRA (Article 14).

If you have a complaint or suggestion about Hunter Dunning’s handling of personal data, then please contact complaints@hunterdunning.co.uk .

Alternatively, you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/

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