Privacy Policy

Welcome to Peninsula’s privacy policy. We appreciate you taking the time to read all our notices carefully.

Peninsula Business Services Limited (“Peninsula”) is committed to protecting your privacy by ensuring that any personal data is collected and used lawfully and transparently. When delivering our professional services such as employment law advice, health and safety services and legal representation, we are the Data Controller of the personal data that you supply to us under your contract with us. When delivering any of our online platforms, such as Business Safe Online, Bright HR and HR Online we are deemed as a Data Processor.

This Privacy Notice explains:

• Who we are
• Personal data we collect
• Our legal basis for processing
• Who we may share information with and why
• Where we may transfer data to
• How we keep information secure and deal with security incidents
• How long we may keep your data for
• Your data privacy rights
• How to contact our DPO and the ICO

If you are an employee of one of our clients looking for further information on how we handle your data, please click here.

Who is Peninsula?

Peninsula Business Services specialises in the provision of HR, Employment law and Health and Safety consultancy services to businesses within the UK and Ireland. The group has global reach, providing a diverse range of clients with access to products and services covering a broad spectrum of legal compliance within the employment field.

When providing these services, we take our responsibilities regarding data protection very seriously and are bound by all applicable data protection laws in respect of the handling, processing and collection of data. All employees who handle personal and business data are fully trained to ensure that the data is processed in line with the General Data Protection Regulations 2018 (GDPR) as well as The Data Protection Act 2018 (DPA 2018).

Personal data we collect

The type and frequency of any personal data collected will always depend on how our website and services are used. If you do not wish to provide us with certain categories of personal data, you may not be able to use our services in their entirety.

Personal Data provided to us:	We use electronic contact forms and chat facilities across our websites. These forms will prompt users to input basic contact details so we can generate service quotes, provide newsletter updates and respond to enquiries. You may also provide data to us when registering for an event, seminar or vacancy or when corresponding with us by phone, email, letter or social media. It is important that the personal data we hold about you is accurate and current. You should keep us informed if your personal data changes during your relationship with us.
Personal Data collected by us:	Where you ask us to provide services, we may be required to process additional categories of personal data relating to you or other parties to ensure the provision of informed legal advice. We may also collect additional data from you as part of our recruitment process, during your employment or when you visit our offices via CCTV. We may also ask to verify your identity in limited circumstances by providing valid photographic identification.
Personal Data from other sources:	We may receive information about you and/or your company from specific third parties such as business partners, sub-contractors, advertising networks, analytics providers, hosting providers and search information providers. Peninsula also receives referrals from other clients and purchases marketing lists from external companies.
Special Categories of Data:	There may be instances where we need to process Special Category Data provided by you or other users of our services during the lifetime of our service. Special category data is a more sensitive type of data which reveals insights about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life, or sexual orientation. We may also process data that relates to criminal and/or civil offences as well as child data in some very limited circumstances, usually in connection with Legal advice or Employee Assistance programs. Sensitive data collection will only take place where it is applicable to the provision of the services that we are contracted to provide. The fundamental rights of the data subjects are always assessed to ensure that the processing is fair, transparent and lawful.
Online Identifiers:	When you visit our website, a record of your device’s IP address is retained which is used anonymously in order to determine website and page visitors. For more information on how we use online identifiers or cookies please visit our cookies policy.

Our legal basis for processing

Before processing any personal data, we ensure that at least one lawful basis under GDPR is met. We will not disclose personal data for any purpose other than what the data was originally collected for; unless there is an overriding legal basis that enables this processing.

We may collect, hold, use and disclose the information collected to compile statistical data and to maintain our database; to develop or improve our website; respond to any queries; notify you of any upcoming marketing, training or other events that we think may be of interest to you; provide you with publications; manage quality control and compliance issues; manage systems administration; provide you or your organisation with advice; notify you about important changes or developments to our services; contact you for your views on our services or to determine the suitability for employment.

We may also process your personal data in the following circumstances:

To Perform Our Service Under the Contract:	We process information in order to support and maintain our existing or potential contractual relationships under the lawful basis ‘performance of a contract’. We may process personal data in order to provide various supporting client services, take payments and to make improvements to our website. We record all calls made to our staff members including internal, inbound or outbound calls. The lawful basis which we often rely on to process data for the duration of servicing on your account and for the decision to enter an initial or any subsequent contract is under our ‘legitimate interests’. Ensuring our administrative and IT systems are secure and robust against unauthorised access also falls under this basis.
For Fraud Prevention:	Due to the products we offer to companies, we also have a ‘legal obligation’ to validate the status of companies we work with which may involve identifying and verifying individual data subjects as part of our ‘legitimate interests’ to safeguard against criminal or fraudulent activities. We also need to ensure that VAT and premium tax is paid.
To Defend Legal Issues:	We have a ‘legitimate interest’ to process data which may assist us in connection with the establishment, exercise or defence of legal claims.
To Process Sensitive Data:	In some cases, where the processing is deemed high risk or highly sensitive, we may ask for your ‘consent’ before we undertake the processing. For example, when providing information on reasonable adjustments before an interview. Where consent is used as the lawful basis for the processing, you will be entitled to withdraw that consent at any time as well as exercise your data privacy rights.
When you apply for a vacancy:	You provide several pieces of data to us directly during the recruitment exercise. In some cases, and to facilitate our ‘Legitimate Interests’ we will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies. Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins. We have a Legal Obligation to ensure you have a right to work in the UK and make reasonable adjustments for you if you have a disability. The ongoing lawful basis we rely on to process your data will be under our legal obligations or legitimate interests which may include assessments made on salary.
For Marketing Purposes:	Peninsula Business Services Limited is one of several companies within The Peninsula Group. There may be occasions where several divisions in the group are involved in the delivery of the services you are contracted to receive. On occasion, we may share data with our affiliated divisions under our ‘legitimate interests’ to enhance the delivery of any services you have. Please refer to the footer of this page for details on the identity of our other group divisions. You can opt out of group marketing by emailing us at: [email protected] As part of our business-to-business sales strategy we may contact companies and individuals of companies about our products and services. To do this, we rely on our shared ‘legitimate interests’ in doing business together. This lawful basis also applies to any purchased data we may use from our various lead sources and when we share your data across our group databases.

for more detailed information on our lead sources please visit the respective company privacy notices below to learn more about their individual data acquisition and handling practices. You can also opt out of updates and marketing by clicking on the unsubscribe button at the footer of our email communications. 118 Data Resource Limited:

Data Sharing and International Transfers

Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial, technological or administrative assistance. When we share data with an external third party; these operations are governed by a Data Processing Agreement (DPA) and we perform regular due diligence on any external companies we work with to ensure that high levels of data integrity are maintained.

Any transfers taking place outside the EEA are only permitted with the provision of an Adequacy decision, Standard Contractual Clauses (SCC’s) or any other lawful transfer mechanism. Where necessary, we may need to share data with external organisations such as law enforcement, regulatory bodies, fraud prevention agencies, partners or advisors. Before any data is shared, we ensure that all technical and organisational controls are firmly in place and a data protection impact assessment is undertaken, where applicable, if the sharing or transfer is considered high risk. We do not sell your data to any third parties.

Data Storage and Security

We have a dedicated Information Security team who are in place to offer protection across all our networks and IT assets to assist with data security and data loss prevention. All our systems are robustly secured, and we are ISO27001 and ‘Cyber Essentials Plus’ certified. We also have a specialised Incident Response Team on hand to respond quickly to any data related issues including the prevention and detection of cyber criminals. For our UK and Irish clients, cloud providers we use have servers based within the UK and EEA jurisdictions. As a company we promote a ‘paperless’ culture where possible.

Data Retention

Companies within the Peninsula Group only keep your data for as long as necessary, unless there is an overriding legal ground. We will not retain data if it is deemed unlawful to do so. Data may be held for purposes relating to the establishment, exercise or defence of legal claims which the group or our clients may face. Where we represent you in any legal case, we retain the data for seven years from the conclusion of the litigation case. We will also typically keep data concerning your account for at least seven years from the date you end your contract with us. Some data may be deleted before this time period depending on the category of that data in line with our commercial legitimate interests and retention schedule, for example, data provided to us in the course of an unsuccessful job application will be retained no longer than 6 months after the recruitment exercise.

Personal data that is no longer necessary is deleted securely in line with Peninsula’s Data Disposal Policy. Our Data Retention and Data Disposal policies are available upon request.

All data subjects have individual rights. On a case by case basis, you have the following rights in relation to your personal data processed by The Peninsula Group:

• The right to be informed about how your personal data is collected and used
• The right to request access to a copy of any personal data that we hold about you
• The right to rectify personal data we may hold which is identified as incorrect or misleading
• The right to erasure of any personal data; also known as ‘the right to be forgotten’
• The right to restrict further processing of your personal data
• The right to data portability where technology allows us to send personal data onto a new controller
• The right to object to the processing or certain processing activities
• Rights in relation to automated decision-making including profiling.

As an organisation we do not operate any automated decision-making systems. Please be aware that the rights listed in this section only apply to individuals and cannot be used to request data relating to business entities. Please be aware that your rights of access do not entitle you to physical or digital copies of any documentation we hold.

Queries and Complaints

Peninsula has a dedicated representative who can be approached for any questions, comments and requests regarding this privacy policy or our Data Privacy Management System. Frequently asked questions about or GDPR compliance can be accessed here.

Our Group Data Protection officer welcomes communication around our policies and practices and they can be directly contacted on the details below, which are also publicly available on the ICO register. You can also write to us at Peninsula Business Services, The Peninsula, Victoria Place, Manchester, M4 4FB.

GDPR Oversight Team: [email protected]

If you’re not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can approach the UK regulator for further guidance at www.ico.org.uk/concerns

Additional Information

This version was last updated and reviewed January 2022.

We regularly review and monitor regulatory guidance for any industry changes which may impact our business operations or your rights and freedoms.

In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier.

We are legally known as Peninsula Business Services Limited, and our registered office is at The Peninsula, Victoria Place, Manchester, M4 4FB, United Kingdom. We are registered in England and Wales under company number 05445673. ICO Registration Number: Z6085670

We form part of a larger group of undertakings known as ‘The Peninsula Group’. Other Companies that sit within our Group of companies within the global group:

Croner (UK), Croner-I (UK), Croner Taxwise (UK), Bright HR (UK), Health Assured (UK), Peninsula Employment Services (Ireland), Graphite HRM (Ireland), Employsure (Australia), Employsure (New Zealand), Peninsula Business Services (Canada).

Copyright © Peninsula Business Services Limited 2020