Shillings Ltd T/A Home and Roost Privacy Notice

Welcome to the Shillings Ltd Privacy Notice.

This Privacy Notice applies to Shillings Ltd and all our subsidiary companies. 

When we mention Shillings Ltd or refer to "we," "us," or "our" in this Privacy Notice, we are referring to the relevant company that is responsible for protecting your personal data.

The relevant Shillings Ltd companies are:

• The Hutch Company 
• Home and Roost

Home and Roost respects your privacy and protects your personal data.  

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA
5. HOW WE USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
11. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you clear and detailed information about:

• how we collect and process your personal data
•  the legal grounds allowing us to do so
•  how we look after your personal data
•  your privacy rights
•   how the law protects you.

Controller

Under data protection law, the controller of your personal data decides how and why your personal data will be processed and takes responsibility for protecting it. The controller of your data will be Home and Roost.

Data Protection Compliance Manager

We have appointed a data protection compliance manager (DPCM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPCM using the details set out below.

Contact details

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

When we issue a new version of this privacy notice, we will post a message on our websites advising you of this.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.  The websites of any of our subsidiary businesses are subject to this privacy policy.

Important information and who we are

We may have to share your personal data with the parties set out below for the purposes set out in the How we use your personal data section. 

Internal Third Parties

Shillings Ltd companies acting as joint/independent controllers or processors and who are based in the UK will share personal information to provide (i) core services to fulfil customer orders, (ii) payment administration services, (iii) employment and services to employees.

External Third Parties 

• HM Revenue & Customs, regulators and other authorities acting as processors
• Cloud-hosted providers
• Professional advisors
• IT technical support services
• Delivery services providers
• Accrediting bodies we enrol with
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

1. The data we collect 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).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows and may use for the purposes set out in the How we use your data section:

• Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, curriculum vitae (CV), cover letter, academic record, employment history and references and images captured by CCTV.
• Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, and genetic and biometric data (we have safeguards for processing such data, including confidentiality agreements and restrictions on access to such data).
• Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
• Contact Data includes your home address, email address and telephone numbers, next of kin and emergency contact information.  
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when accessing our website www.homeandroost.co.uk or any of the websites of our subsidiaries accessed from that website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our websites and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose.  Where Aggregated Data can directly or indirectly identify you we will use it in accordance with this Privacy Notice.

 If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

1. How is your personal data collected?

We use different methods to collect personal data from and about you including through:

Direct interactions. You may give us your personal data by filling in application forms, by sending us your CV and covering letter or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you  

• create an account on our website;
• request marketing information is sent to you
• apply for a job;
• complete a survey;
• Provide to us during our communications with you or
• give us some feedback.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as those set out below:

• Named Referees – Identity Data and Contact Data
• Recruitment agencies – Identity Data and Contact Data
• Disclosure and Barring Service – Criminal Conviction Data
• Providers of technical, payment and delivery services – Contact, Financial and Transaction Data.
• Technical Data from the following parties:

Automated technologies or interactions. As you interact with our website, we may automatically (with your consent where consent is required) collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.

1. Our legal basis for using your personal data

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

• Where it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).
• Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).
• Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).
• Where you have given us your consent to process your personal data (CONSENT).
• Where there is an emergency situation, for example, if you need emergency medical treatment (VITAL INTERESTS).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending third-party direct marketing communications to you via email or text message.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You have the right to withdraw your consent at any time by contacting us. 

Please see Section 10: Your legal rights

How we use your personal data

Purpose/Activity	Type of Data	Lawful Basis for Processing
PROSPECTIVE CUSTOMERS
To register you on our website and subscribe to our services	Identity, Contact, Marketing and Communications Data	Contract, Explicit Consent
To process your order form and correspond with you including: (i) arranging deliveries (ii) ongoing issues or complaints	Identity, Contact, Financial	Contract
Provision of personal data to third parties for online conversion service where a customer has started the application process but does not complete it	Identity, Contact	Legitimate interests (securing applications for its courses)
ENGAGED CUSTOMERS
To register you for our services as an engaged customer	Identity, Contact, Financial, Transaction	Contract
To provide you with ongoing services after engagement including: (i) provision of generating the order (ii) administration, processing fees, managing the order (iii) providing services, IT and information services and other customer support	Identity, Contact, Financial	Contract
To provide you with updates on your order	Identity, Contact	Contract
To provide you with information on ongoing products relating to your purchase	Identity, Contact	Legitimate interests (promotion and marketing of products)
To process customer complaints and grievances	Identity, Contact	Legitimate interests (investigating and resolving complaints)
To carry out internal research and statistical analysis	Identity	Legitimate interests (monitoring and evaluating product performance)
To capture images on CCTV used by head office, factory locations	Identity	Legitimate interests (security and crime prevention)
To take photographs and videos of customers for marketing purposes (including brochures, website, promotional videos)	Identity	Explicit Consent
Provision of personal data to third parties
To enable our companies to provide (i) completing customer orders (ii) delivering orders (iii) process customer issues or complaints	Identity, Contact, Financial, Transaction	Legitimate interests (necessary for providing services)
To courier companies who provide delivery services	Identity, Contact	Legitimate interests (outsourcing services)
To insurance companies worldwide who provide Home and Roost with insurance policies	Identity, Contact	Legitimate interests (third-party insurance providers)
To medical authorities in case of emergency where you are incapable of giving consent	Identity, Contact	Vital Interests
To medical authorities in the event of an emergency and where we are legally obliged to comply	Identity, Contact	Special Category, Legal obligation
To providers of activities for customers	Identity, Contact	Special Category, Legitimate interests (offering various activities)
To providers of incentive schemes for customers	Identity, Contact	Legitimate interests (providing incentive schemes)
To HM Revenue & Customs for reporting of financial processing activities (UK)	Identity, Contact, Financial, Transaction	Legal obligation
To service providers worldwide who provide IT and system administration services, including cloud-hosted providers	Identity, Contact	Legitimate interests (business requirement for third-party services)
To professional advisors (e.g. lawyers, bankers, insurers, auditors)	Identity, Contact, Financial, Transaction	Special Category, Legitimate interests (specialist professional advice)
To the Police regarding the prevention or reporting of a crime	Identity, Contact	Special Category, Legal obligation or Vital interests (depending on the circumstances)
EMPLOYMENT CANDIDATES
To assess your skills, qualifications, and suitability for the role	Identity, Contact	Contract
To assess disability status to consider appropriate adjustments during recruitment	Special Category	Consent
Once an offer has been made to carry out background and reference checks (excluding criminal record)	Identity, Contact	Contract
Once an offer has been made to carry out a criminal record check where required by law	Identity, Criminal Conviction	Legal obligation
To communicate with you about the recruitment process	Contact	Contract
To comply with equal opportunities monitoring and reporting requirements	Identity, Special Category	Legal obligation
ALL VISITORS TO THE WEBSITE
To deliver relevant website content and advertisements, measure effectiveness	Identity, Contact, Profile, Usage, Technical, Marketing and Communications	Legitimate interests (marketing strategy)
To use data analytics to improve website, services, marketing, customer relationships	Technical, Usage	Legitimate interests (business development)
To make suggestions and recommendations to you about services that may be of interest	Identity, Contact, Technical, Usage, Profile	Legitimate interests (developing services and growing the business)
Provision of personal data to third parties
To service providers worldwide acting as processors who provide IT and system administration services	Identity, Contact, Technical, Usage, Profile	Legitimate interests (business requirement for third-party IT and system administration)
To third parties to whom we may sell, transfer, or merge parts of our business or assets	Identity, Contact	Legitimate interests (business strategy)

Marketing

We strive to provide you with choices regarding specific personal data uses, particularly around marketing and advertising.  

You will receive marketing communications from us if you have explicitly consented to receive, requested information from us, purchased services/products from us, provided us with your details when you entered a competition or registered for a promotion, and have not opted out of receiving that marketing.

Types of marketing we use will include but is not limited to; emails, text messages, flyers, social media platforms.

Third-party marketing

We will obtain your expressed opt-in consent before sharing your personal data with any company outside the Shillings Ltd subsidiaries for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to service messages that are not direct marketing.

Change of purpose

We will only use your data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. Disclosures of your personal data

You will have given us some of your personal information when you use our services or purchase a product. 

While you must usually provide us with personal information we need to collect, there are some occasions when you can choose whether or not to, such as details about your marketing preferences. We will always tell you if it's optional. If you must provide the information, we will explain what might happen if you don't. 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Internal Third Parties

• Shillings Ltd. companies acting as independent controllers or processors and who are based in the UK, provide (i) process customer orders, (ii) issue or complaint resolution.

External Third Parties

• Courier companies
• Accommodation providers
• Insurance provider
• Medical or Public Health authorities (and where an emergency situation to any other organisations/individuals deemed necessary as assessed at the time)
• Amazon, eBay, Etsy
• Local authorities
• Local councils  
• HM Revenue & Customs, regulators and other authorities acting as processors
• Service providers worldwide acting as processors
• Cloud-hosted providers
• Professional advisers worldwide acting as processors or joint controllers.
• Local authorities
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. International transfers

We share your personal data within the Shillings Ltd group. This may involve in some cases transferring your data outside  of the Uk or European Economic Area (EEA).

Some of our external third parties are based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure it receives additional protection as required by law. To keep this privacy notice as short and easy to understand as possible we havent set out the specific circumstances when each of these protection measure are used. You can contact is for more information.

1. Data security

The personal data that we collect from you will be stored:

• in the secure data centre of our IT and system administration service provider

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

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

1. Data retention

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in the table below: 

Type of Data	Retention Timescale
Customer Records
1. Customer – Recruitment
Enquiries from prospective customers	1 year from last sales activity
Records of campaigns and events	1 year from last sales activity
Customers – Completed
Online Order Forms	Completion of purchase + 3 years
Email Order Forms	Completion of purchase + 3 years
Copies of invoices	7 Years after date of Withdrawal
Basic customer record (name, address, email, telephone number, transcript data)	Permanently
Accident/incident records of customers/staff/visitors	3 years from the date of accident/incident
Accident/incident records in the event of asbestos exposure	40 years
CANDIDATE RECORDS
Application forms, CVs, interview notes (unsuccessful candidates)	Last communication to candidate + 6 months
Application forms, CVs, interview notes (successful candidates)	Part of the personnel file. 6 years after employment ceases

 

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data – (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data – (commonly known as the “right to be forgotten”).  This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data – 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data – (also known as the “right to data portability”) We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Compliance Manager, Alan Brimm in writing with full details of your request.  You can send an email to alan@homeandroost.co.uk or you can write to us at:-

Data Protection Compliance Manager Postal address: Home and Roost, The Hanger, The Loop, Manston, Kent, CT12 5DE

No fee is usually required

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.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Last updated 19/10/2024