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 Shillings Ltd T/A Home and Roost Privacy Notice

Introduction

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 then 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 is committed to protecting 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 looking after your personal data.  The controller of your personal 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

Full name of legal entity: Shillings Ltd T/A Home and Roost 

ICO Registration Number: ZA797494

Name or title of DPCM: Alan Brimm

Email address: [email protected]

Postal address: Home and Roost, The Hanger, The Loop, Manston, Kent, CT12 5DE

 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 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.

  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 together as follows:

  • 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), covering 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, genetic and biometric data (we have in place 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 data from and about you including through:

Direct interactions. You may give us your Identity Data, Special Category Data, Criminal Conviction Data, Contact Data and Financial 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; 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:

(a)     analytics providers;

(b)     advertising networks; and

(c)      search information providers.

Automated technologies or interactions. As you interact with our website, we may automatically 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 needed 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

  1. How we use your personal data

Prospective Customers

PROSPECTIVE CUSTOMERS  
Purpose/ActivityType of DataLawful basis for processing
To register you on our website and subscribe to our servicesIdentity

 

Contact

 

Marketing and Communications Data

Contract

 

 

 

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  
To a third party online conversion service where a customer has started the application process but does not complete it.Identity

 

Contact

Legitimate interests (the company has a business interest in securing applications for its courses)

Engaged Customers

ENGAGED CUSTOMERS   
Purpose/ActivityType of DataLawful basis for processing
To register you for our services as an engaged customerIdentity

 

Contact

Financial

Transaction

 

Contract
To provide you with ongoing services after engagement including:

 

(i) provision of generating the order

(ii) administration including maintaining customer records, processing fees, managing the order

(iii) providing services including, IT and information services and other customer support services

Identity

 

Contact

Financial

Contract

 

 

To provide you with ongoing services after engagementIdentityContract

 

 

To provide you with updates on your orderIdentity

 

Contact

Contract

 

 

To provide you with information on ongoing products relating to your purchaseIdentity

 

Contact

Legitimate interests (It is in the interests of the customer for the company to provide this information and has a business benefit with regard to promotion and marketing of its products)
To process customer complaints and grievancesIdentity

 

Contact

 

 

Legitimate interests (It is in the interest of both parties for us to investigate and attempt to resolve complaints and grievances)

 

 

To carry out internal research and statistical analysis  IdentityLegitimate interests (to monitor and evaluate the performance and effectiveness of our products)
To capture images on CCTV used by head office, factory locationsIdentityLegitimate interests (the company has an organisational requirement to maintain the security of its premises and for the prevention and investigation of crime)
To take photographs and videos of customers for marketing purposes (including for use in brochures, on our website and in promotional videos)IdentityConsent
Provision of personal data to third parties  
Internal  
To enable our companies to provide (i) completing customer orders (ii) delivering customer orders (iii) process customer issues or complaintsIdentity

 

Contact

Financial

Transaction

 

 

 

Legitimate interests (The transfer is necessary to enable us to provide our services.  All our subsidiaries are subject to this privacy policy and other relevant policies and procedures.)
External  
To provide ongoing customer support servicesIdentity

 

Contact

Legitimate interests (It is appropriate for us to share this information with these interested parties for us to manage the customer orders, complaints and resolutions)
To courier companies who provide delivery servicesIdentity

 

Contact

Legitimate interests (We have a valid business requirement to outsource this service.  The company has contracts with all its approved courier companies.)
To insurance companies worldwide who provide Home and Roost with insurance policiesIdentity

 

Contact

Legitimate interests (The company cannot provide insurance policies itself and therefore needs to recommend a third-party provider)
To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency where you are incapable of giving consentIdentity

 

Contact

 

 

 

Special Category

Vital Interests

 

 

 

 

 

Vital Interests

To medical authorities (and any other organisations/individuals deemed necessary as assessed at the time) in the event of an emergency and where we are legally obliged to comply with a request for disclosureIdentity

 

Contact

 

 

Special Category

Legal obligation

 

 

 

 

Legal Obligation & Public Interest (in the area of public health)

To providers of activities for studentsIdentity

 

Contact

 

 

 

Special Category

Legitimate interests (The company offers various activities as part of its courses and cannot provide these activities itself)

 

 

Consent

To providers of incentive schemes for customersIdentity

 

Contact

Legitimate interests (The company offers incentive schemes as part of its promotional offers and cannot provide these schemes itself)
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 servicesIdentity

 

Contact

 

Legitimate interests (We have a business requirement to use third party providers for specialist services)

 

 

Professional advisors subject to a duty of confidentiality (e.g. lawyers, bankers, insurers, auditors)Identity

 

Contact

Financial

Transaction

 

Special Category

Legitimate interest (We have a business requirement to seek specialist professional advice that cannot be provided internally)

 

 

 

Consent

To the Police regarding connection with the prevention or reporting of a crime.Identity

 

Contact

 

 

 

Special Category

Legal obligation or Vital interests (depending on the circumstances)

 

 

 

 

Legal obligation or Vital interests (depending on the circumstances)

 

Employment Candidates

EMPLOYMENT CANDIDATES  
Purpose/ActivityType of DataLawful basis for processing
To assess your skills, qualifications and suitability for the roleIdentity

 

Contact

Contract

 

 

To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment processSpecial CategoryConsent
Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record)Identity

 

Contact

Contract

 

 

Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied forIdentity

 

 

Criminal Conviction

Contract

 

 

Legal obligation

To communicate with you about the recruitment processContactContract
To comply with equal opportunities monitoring and reporting requirementsIdentity

 

 

Special Category

Legal obligation

 

 

Legal obligation and necessary for statistical purposes

 

All visitors to website

ALL VISITORS TO WEBSITE  
Purpose/ActivityType of DataLawful basis for processing
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity

 

Contact

Profile

Usage

Technical

 

Marketing and Communications

Legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy)

 

 

Consent

To use data analytics to improve our website, services, marketing, customer relationships and experiencesTechnical

 

Usage

Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to youIdentity

 

Contact

Technical

Usage

Profile

 

Legitimate interests (to develop our services and grow our business)
Provision of personal data to third parties  
External  
To service providers worldwide acting as processors who provide IT and system administration servicesIdentity

 

Contact

Technical

Usage

Profile

Legitimate interests (We have a business requirement to use specialist IT and system administration providers that cannot be provided internally)
To third parties to whom we may choose to sell, transfer or merge parts of our business as our assets.Identity

 

Contact

Legitimate interests (We may wish to do this as part of our business strategy)

Marketing

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

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

Third-party marketing

We will get your express opt-in consent before we share 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 at any time 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 personal data provided to us as a result of purchasing a service or other transaction.

Change of purpose

We will only use your personal 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

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 joint 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 the European Economic Area (EEA).

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

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (as at the date of this Privacy Notice this applies to Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay).
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.  
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US, or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, with standard contractual clauses.  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
  1. Data security

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

  • in our own secure data centres in the UK; and
  •  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 dataRetention timescale
Customer Records 
1. Customer – Recruitment 
Enquiries from prospective students1 year from last sales activity
Records of campaigns and events1 year from last sales activity
2.Customers– Completed 
Online Order FormsCompletion of purchase + 3 years
Email Order FormsCompletion of purchase + 3 years
Copies of invoices7 Years after date of Withdrawal
Basic customer record comprising of customer name, address, email, telephone number and transcript dataPermanently
Accident/incident records of customers/staff/visitors3 years from the date of accident/incident

 

40 years in the event of exposure to asbestos

 

CANDIDATE RECORDS 
Application forms, CVs and interview notes (unsuccessful candidates)Last communication to candidate + 6 months
Application forms, CVs and interview notes (successful candidates)Part of the personnel file.  6 years after employment ceases.

 

In some circumstances you can ask us to delete your data: see Request erasure in Section 10 Your legal rights for further information.

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.

  1. 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 [email protected] 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 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 19/10/2020