OFF TO WORK STAFF PRIVACY NOTICE

Your Privacy is Important to Us

Off to Work is committed to protecting your privacy and legal rights when dealing with your personal information. This Privacy Notice (together with your Casual Worker Agreement) intends to provide clear and understandable details about the information we collect about you, how we use, share and protect it.  

If you have any queries about this Privacy Notice, if you are not sure what something means, or if you wish to contact us about personal information we hold, please email us at [email protected]. We ask that you please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who We Are

“Off to Work”, “we”, “us”, “our”, “the Company” refers to Off to Work, a trading name of Navolio Ltd. Registered in England and Wales. Registered number 03760009 and registered address: 4 Chiswell Street, London EC1Y 4UP. “You”, “your” refers to the individual registered to work through Off to Work. Off to Work is registered with the Information Commissioners Office, registration number Z2961236.

Off to Work is a staffing solutions provider, offering hospitality staffing, recruitment, consultancy and training. The Company must process personal data (including sensitive personal data) so that we can provide these tailored services. In doing so, the Company acts as a data controller and/or processor. For the purposes of providing you with work-finding services, training, work assignments and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.

Collection and Use of Personal Data

We comply with GDPR obligations by storing and destroying your personal data securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure; by ensuring that appropriate technical measures are in place to protect personal data and we ask you to keep your personal data up to date.

You may give your personal details to Off to Work directly through our online registration form, through third-party job boards, enrolment paperwork, by visiting our website, app, marketing emails, social media, postal communications, by email, telephone and/or face to face. Indirectly, the Company may collect your data from third parties which may include referees, job boards, clients, HMRC. The Company must have a legal basis for processing your personal data.

What personal data do we collect?

Please find below a more detailed look at some or all of the information we may collect. The information described below is in addition to any personal data we are required by law to process in any given situation. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data;

• Name;
• Date of birth;
• Gender;
• Headshot;
• Uniform size;
• Contact details;
• Employment history;
• Emergency contact details;
• Medical disclosure details;
• Referee details;
• Immigration status (and permit details);
• Nationality, citizenship and place of birth;
• National Insurance number;
• A copy of your passport/identity card and/or driving licence;
• A copy of your proof of bank account details;
• DBS (Disclosure & Barring Service) certificate details;
• Details of any criminal convictions;
• Details about your current pensions and benefits arrangements;
• Information of your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
• Training records;
• Client and work history;
• Payment history and payroll number;
• Extra information that you choose to tell us;
• Extra information that your referees choose to tell us about you;
• Extra information that our clients may tell us about you;
• IP address; and
• The dates, times and frequency with which you access our services.

Purpose of processing

To enable us to fulfil our contractual duties to you and to our clients, the Company will collect and process your personal data (which may include sensitive personal data) to provide you with work assignments and ancillary support services. The more data we have about you, such as your availability, your skillset, your goals etc, the more we can understand the best way to work with you and offer the most appropriate work assignments.

To ensure your wellbeing and to ensure the Company complies with its health and safety obligations, Off to Work may share serious medical conditions with clients where it deems appropriate. Your medical information is classified as sensitive personal data and it is only with your consent that we would normally share this data, unless it is to protect your life. In these circumstances we are processing your sensitive personal data under the lawful basis of vital interest. 

We may also use your information to review and analyse how to improve the services. 

Off to Work would also like to use your contact information for internal marketing campaigns; promoting opportunities; sending company news, product updates, launches and invitations; gathering feedback and any other relevant information by email and text message. To give consent to the use of your data for these purposes, please tick the marketing communications opt-in box at the bottom of this notice.

You have the right to withdraw consent for the use of your personal data in direct marketing, however, it may affect your chances to be informed about work opportunities and company updates. To windraw consent simply untick the opt in box at any time under the My Data tab of your Off to Work account or email our marketing team on [email protected].

Occasionally, we may wish to use photographs of you at our events or the images provided/taken during your registration process. This will be for marketing purposes on our website and other mediums. If you do not consent to the use of your image please email our marketing team at [email protected].

Who we share your data with

The nature of our business requires us to share your information with our clients to complete contractual obligations. This includes your name, photograph and uniform size which is disclosed for identification at work, confirmation of hours and issuing of uniform, amongst other reasons. For some work assignments this may also include security details, to be processed through background checking for work of a high security nature.

Off to Work may share your information with service providers who help us to provide services to you; or when required by law (i.e. when providing tax and earning details to Her Majesty’s Revenue & Customs); or when it is required by a competent authority in the exercise of its duties (i.e. to investigate, prevent or act on illegal activities) or when we have your permission i.e. when requesting a reference.

Third parties are required to comply with our Privacy Notice and any other adequate technical and organisation measures. We contractually bind these service providers to the corresponding Data Processing Agreement to ensure your information is kept confidential and used only to the extent required by them to perform the services that we request and in accordance to the applicable privacy legislation. We do not sell your data to third parties.

Legal basis for processing

Off to Work’s use of your data for the purposes described above is based on the following legal bases;

Consent

Consent will be requested upon registering your interest to join Off to Work. Only once consent has been freely given will we contact you to complete your enrolment to Off to Work. You have the right to withdraw consent at any time, however this may lead to our inability to offer you further work assignments. To withdraw consent, simply email [email protected]

Consent is also requested to use your contact details for direct marketing, which can be freely given and withdrawn at any time by updating your marketing preferences in your My Data page.

Contractual/Legal requirement

We are entitled to use your data to fulfil contractual obligations with you, or where it is required by law and/or a contractual requirement (i.e. when our clients require your personal data). You are obliged to provide the personal data and if you do not the consequences of failure to provide the data is the inability to be offered assignments through Off to Work.

Legitimate interest

Article 6(1)(f) of the GDPR states that we can process your data where it is “necessary for the purposes of the legitimate interests pursued by (us) or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of (you) which require protection of personal data.”

We don’t think that the following activities prejudice individuals in any way, instead we believe that they enable us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis.

We deem the following activities as necessary within the range of our legitimate interests;

• it’s reasonable for us to process your data to make sure that we send you the most appropriate options.
• Where needed, to provide you with transport and accommodation associated with a work assignment we also believe it is necessary for us to process your personal data.
• For the business to operate we need to use your data for internal administrative activities, such as security clearance background checking, payroll and invoicing. We also hold your financial details, so that we can pay you for your services.

Vital interest

We may deem it necessary to share your medical details to protect your life. 

Recipient/s of data

The Company may process your personal data and/or sensitive personal data with some/all of the following recipients: Hubspot, Mailchimp, Typeform, Survey Monkey, Eventbrite, Google Documents, Calendly, Dropbox, UCheck, List99, UKVI, TrustID, Text Anywhere, Interserve, the Career Centre, Achilles, LevelUp, Time Target, Etips, Comensura, JP Morgan, Accredit Solutions, Depol, Flow, HMRC, Department of Work & Pensions, Child Maintenance Service, HM Courts & Tribunal Service, RSM UK, Nest, Trainline.com, Enterprise Rent a Car, A2B Radio Cars, Cedar Cars, Uber, Apollo Minibus Hire, Wheadon Coach Hire, Assist VIP Coach Travel, Admiral Minibus Hire, Thrifty Car Rental and Chez Route.

Overseas Transfers

We want to make sure that your data is stored and transferred in a way that is secure. For the purposes of providing you with assignments outside of the European Economic Area or EEA (The Member States of the European Union, together with Norway, Iceland and Liechtenstein), we will therefore only transfer data outside of the EEA where it is compliant with data protection legislation and the means of the transfer provides adequate safeguards in relation to your data.

Data Retention

The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive personal data (including your name, address, date of birth, place of birth, right to work information including your passport/visa details), we will do so in line with our retention policy, please email [email protected] if you would like a copy of this policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

Your Rights

You have the following data protection rights, however please note, that the rights are not absolute. The only absolute right you have is to request that we do not use your personal information for direct marketing.

Please do contact us if you are unsure about your rights as detailed below. We will always endeavour to help explain how your rights apply to the personal information we process, for our specified lawful reasons.

The right to be informed about the personal data the Company processes on you. We are obliged to provide this in a clear and concise manner;

The right to access to the personal data the Company processes on you; This is known as a Subject Access Request or ‘SAR’. You also have the right to request a copy of your personal data that we process.

We will need to identify you using reasonable means before we will start the process of collating your personal information. Once we have identified you, we will reply to any requests for your personal information (SARs) within 30 days, unless we deem the request to be complex, or repetitive, where we will notify you that we may take up to an additional two months to provide your personal information.

We will not charge you to request information from us. However, we will charge a reasonable fee (considering the administrative costs of providing the information) if the request for information is repetitive. If we’ve provided information to you and you wish to request it again, we ask that you contact us beforehand to discuss what our reasonable fee is. 

Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so;

The right to rectification of your personal data. However, we can only consider requests to correct factual information;

The right to erasure of your personal data in certain circumstances. If you have subscribed to any of our marketing correspondence, you have the right to request erasure from our email list. We will only use your personal information to send you marketing material if you have given us your explicit permission; 

The right to restrict processing of your personal data. This means that we will stop actively processing it, and it will just be stored. Stopping processing will mean that we will not add any additional information to your existing information;

The right to data portability in certain circumstances; 

The right to object if processing of your personal data is based on legitimate interests, or if processing is being used for direct marketing;

To not be subjected to automated decision making and profiling. We do not make any kinds of automated decisions or perform any profiling with your personal information;

The right to withdraw consent at any time;

To make things easier for you to exercise the above-mentioned rights, simply send a request to our Compliance team at [email protected]. Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by again emailing [email protected] or by post to Off to Work, 4 Chiswell Street, London EC1Y 4UP.

Changes to the Privacy Notice

We reserve the right to amend this Privacy Notice from time to time. Amended policies will be published through your Off to Work account, where you may be required to accept the Privacy Notice upon logging in. If you do not agree to the new Privacy Notice, you may terminate your account at any time by emailing [email protected].

Complaints or Queries

If you wish to complain about this Privacy Notice or any of the procedures set out within it, please contact our Data Protection Officer, Guy Dorey on [email protected] or by post to Off to Work, 4 Chiswell Street, London EC1Y 4UP.

You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK or if you believe that your data protection rights have not been adhered to.