Privacy Policy

Privacy Notice

IM HR Consulting Limited is registered in England with Registration Number 15335379 at the Registered address of Booksmart Accounting (49), Bridgeside, Carnforth, Lancashire, LA5 9LF. 

IM HR Consulting Limited understands that your privacy is important to you and that you care about how your personal data is collected, stored and used. We respect and value the privacy of everyone.

Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of our Privacy Notice is deemed to occur upon your first use of our services, including enquiries for further information.

This Privacy Notice describes why and how we collect and use your personal data and provides information about your rights.

Please also use the Key Terms Glossary to understand the meaning of some of the terms used throughout this Privacy Notice. 

A Privacy Notice is a legal requirement of the Data Protection Act (2018), Part 2, within the UK GDPR ‘Right to be Informed’. This Privacy Notice should be read alongside any additional Terms and Conditions. 

This Privacy Notice was last updated in December 2024.

1.0 Key Terms

1.1 Whilst every effort has been made to outline our responsibilities to you in as clear, concise, and easy to understand manner as possible, we do need to use certain terms throughout this Privacy Notice. 

1.2 We will now provide an easy-to-understand definition of each term:

  • Business Continuity Plan (BCP): This is a prevention and recovery system for potential threats, such as natural disasters or cyberattacks. A BCP is designed to protect personnel and assets and make sure they can function quickly when a disaster strikes.
  • Data Controller: A Data Controller has the responsibility of deciding how personal data is processed, the purpose for the data processing, and how to securely protect the personal data.
  • Data Processing Agreement (DPA): Whenever a Data Controller uses a Data Processor to process personal data on their behalf, a written contract needs to be in place between the parties. Similarly, if a processor uses another organisation (i.e. a Sub-Processor) to help it process personal data for a Data Controller, it needs to have a written contract in place with that Sub-Processor. This is commonly referred to as a DPA.
  • Data Processor: In a similar way to Data Controllers, Data Processors must protect people’s personal data. However, they only process it in the first place on behalf of the Data Controller. They would not have any reason to have the personal data if the Data Controller had not asked them to do something with it. 
  • Data Protection Act (DPA 2018): The DPA 2018 sets out the legal data protection framework in the UK. It contains three separate data protection regimes:
    • Part 2: sets out a general processing regime (the UK GDPR);
    • Part 3: sets out a separate regime for law enforcement authorities; and
    • Part 4: sets out a separate regime for the three intelligence services.
  • Data Subject: A Data Subject is a living person who can be identified from personal data.
  • Incident Response Plan (IRP): This is a document that outlines an organisation’s procedures, steps, and responsibilities of its incident response programme, for example when responding to a personal data breach.
  • Individual Rights: In UK data protection law, individuals have rights over their personal data. These rights allow the individual to ask the Data Controller to do something or stop doing something with their personal data. There are eight individual rights.
  • Information Commissioner’s Office (ICO): The Information Commissioner’s Office (ICO) is the UK’s independent body set up to uphold information rights.
  • Lawful Basis: A lawful basis is the legal reason or legal grounds relied upon for the processing of an individual’s personal data. There are six lawful bases to choose from: consent, contract, legal obligation, legitimate interest, public task, and vital interests.
  • Personal Data: Personal data is information about who you are, where you live, what you do, and more. It is all information that identifies you as a Data Subject.
    • Privacy and Electronic Communications Regulations 2003 (PECR): PECR sits alongside the DPA 2018 and the UK GDPR. This legislation gives people specific privacy rights in relation to electronic communications, and electronic processing of their personal data.
    • Processing: Processing means taking any action with someone’s personal data, including processing the data for a specific purpose, storing the data, and archiving the personal data.
    • Sub-Processor: A Sub-Processor acts under the instructions of the Data Processor, meaning that they may process individuals’ personal data on behalf of the Data Processor. IM HR Consulting Limited will always seek the permission of the Data Controller before appointing any Sub-Processors.
  • UK GDPR: This stands for General Data Protection Regulation (GDPR), the UK’s agreed standards for data protection that are also written into UK law through the Data Protection Act 2018 (DPA 2018). 

2.1 The scope for IM HR Consulting Limited is any Data Subject, whose personal data is processed upon instruction, in line with UK data privacy legislation including the DPA 2018, PECR (2003), and UK GDPR. 

2.2 We also acknowledge any additional responsibilities requested by the industry regulator in the UK, the Information Commissioner’s Office (ICO).

2.3 The DPA 2018 and UK GDPR have a material scope covering personal data that is processed either electronically or is processed as part of a physical paper filing system.

2.4 IM HR Consulting Limited will adhere to the seven UK GDPR data processing principles when handling personal data:

  • Lawfulness, Fairness, and Transparency;
  • Purpose Limitation;
  • Data Minimisation;
  • Accuracy;
  • Storage Limitation;
  • Integrity and Confidentiality (Security); and
  • Accountability.

2.5 All associates and employees of IM HR Consulting Limited who interact with Data Subjects are responsible for ensuring that this Privacy Notice is drawn to their attention, at the earliest available opportunity.

3.1 IM HR Consulting Limited is a Limited Company, based in England, complying with the laws of England & Wales, paying further reference to the Companies Act (2006).

3.2 IM HR Consulting Limited is registered with the ICO under registration number ZB662393.

3.3 IM HR Consulting Limited acts as a Data Processor and Data Controller. We are responsible for the personal data that we process (on behalf of the Data Subject) and have our own measures for ensuring compliance with the UK data controller regulations (personal data we are responsible for).

3.4 IM HR Consulting Limited also determines the scope of the personal data processing, what personal data we process, and for what purpose.

3.5 From time to time we may appoint Data Processors on behalf of IM HR Consulting Limited. We will always ensure that a written agreement is in place with each of our Data Processors documenting how personal data will be processed, safeguarded, and stored. These Data Processors may be located outside the UK. IM HR Consulting Limited has the overall responsibility for all Data Processors.

3.6 IM HR Consulting Limited has a duty of care acting as a Data Controller to appoint a UK based Data Protection Officer (DPO). We have a legal obligation to notify the ICO of their name and contact details. Our appointed Data Protection Officer (DPO) is CSRB Limited. They can be contacted via email at [email protected]. 

3.7 IM HR Consulting Limited uses lawful bases, as set out in UK GDPR Article 6, when we process your personal data:

  • Contract – personal data is processed by us for the purposes of supplying our bespoke employee retention services to businesses throughout the UK.
  • Legal Obligation – personal data is processed by us to meet a requirement set out in UK law or statute. For example we are legally required to meet the UK anti-money laundering regime requirements as set out in the Proceeds of Crime Act 2002 (POCA) (as amended by the Serious Organised Crime and Police Act 2005 (SOCPA)), the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) and the Terrorism Act 2000 (TA 2000) (as amended by the Anti-Terrorism, Crime and Security Act 2001 (ATCSA 2001) and the Terrorism Act 2006 (TA 2006)).
  • Legitimate Interests – personal data is processed by us to communicate with you regarding important business or commercial information (such as updates to this Privacy Notice), and to inform you of complementary services provided by us.

3.8 IM HR Consulting Limited may process certain Special Category Data on behalf of our clients. This may include the following categories of personal data:

  • personal data revealing racial or ethnic origin;
  • personal data revealing political opinions;
  • personal data revealing religious or philosophical beliefs;
  • personal data revealing trade union membership;
  • genetic data;
  • biometric data (where used for identification purposes);
  • data concerning health;
  • data concerning a person’s sex life; and
  • data concerning a person’s sexual orientation.

3.9 IM HR Consulting Limited ensures that all processing of the above Special Category Data is lawful, fair, transparent, and complies with all the data processing principles of the UK GDPR.

3.10 IM HR Consulting Limited can only process Special Category Data if we can meet one of the specific conditions in Article 9 of the UK GDPR. We may also have to meet additional conditions set out in the DPA (2018). The Article 9 condition we use is Explicit Consent.

4.1 IM HR Consulting Limited processes personal data in a fair way. We do this by putting the individual’s rights at the heart of all processing with regards to personal data. 

There are eight individual rights:

  • Right to be informed – Data Subjects have the right to know why we are collecting and processing personal data, this right is met by the provision of this Privacy Notice and any subsequent privacy documentation;
  • Right of access – you have the right to know what personal data we have on record and request a copy;
  • Right of rectification – you have the right to correct personal data that we hold about you that is inaccurate or incomplete;
  • Right to be forgotten – in certain circumstances you can ask for the personal data we hold about you to be erased from our records;
  • Right to restriction of processing – where certain conditions apply you have a right to ask us to only process your personal data for certain processing activities;
  • Right of portability – you have the right to have the personal data we hold about you transferred to another Data Controller;
  • Right to object – you have the right to object to certain types of data processing such as marketing; and
  • Right to object to automated processing, including profiling – you also have the right to object to the legal effects of automated processing or profiling.

4.2 IM HR Consulting Limited will only handle personal data in ways that individuals would reasonably expect and not use it in ways that have unjustified adverse effects on them. 

4.3 IM HR Consulting Limited will obtain personal data in a fair way. We will seek explicit consent from the Data Subject or securely transfer personal data into the business where a lawful base for processing can be identified from Article 6 of the UK GDPR, as identified in clause 3.7 above.

4.4 IM HR Consulting Limited always considers the rights and freedoms of Data Subjects when processing personal data. This could be for individuals or those part of a wider group. 

5.1 Transparency is fundamentally linked to fairness. IM HR Consulting Limited will always be clear, open, and honest with people from the start, about who we are, and how, and why we need to use your personal data.

5.2 IM HR Consulting Limited will inform Data Subjects from the outset regarding the types of personal data we need to process, usually within our business terms, contract and engagement documentation, this Privacy Notice, and other privacy documentation.

5.3 IM HR Consulting Limited processes the following personal data types as a minimum:

  • Name;
  • Email address;
  • Address;
  • Telephone number;
  • Financial Data;
  • Employment Status;
  • Gender;
  • Ethnicity Data;
  • Disability data;
  • Age;
  • Images (photos or videos);
  • Feedback you provide regarding the services received; and
  • Any other information that you choose to share during the course of communicating with us or accessing the HR support services.

5.4 IM HR Consulting Limited informs individuals about all personal data processing in a way that is easily accessible and easy to understand, using clear and plain language. 

5.5 IM HR Consulting Limited hopes we can resolve any query or concern you raise about our use of your personal data. IM HR Consulting Limited has appointed a certified independent Data Protection Officer (DPO) to act in the interests of all parties. Should you require further information with regards to personal data processing and the protection of your personal data, please contact our DPO via email at [email protected]. 

5.6 Should we not be able to resolve the complaint, you have the right to lodge a complaint with the lead authority. The lead authority in the UK is the Information Commissioner’s Office (ICO), who may be contacted by telephone on 0303 123 1113 or by visiting www.ico.org.uk. 

6.1 IM HR Consulting Limited will always be clear about what the purpose is for any personal data processing from the very start. We use your personal data for administration, delivery, reporting, marketing and research purposes. This includes:

  • To provide you with services as agreed and in our contract with you;
  • To inform you of our complementary services;
  • To facilitate communication with you regarding your contracted services;
  • Understanding the challenges that your business is facing and what you would like to achieve so that we can design bespoke packages of support;
  • Sending you reminders about upcoming meetings/sessions/workshops that you have booked with us;
  • Keeping records of support services you have accessed, and the support provided to you;
  • Referring you to follow-up and complementary support services, where you have given us your consent;
  • Responding to enquiries or complaints;
  • Improving our services;
  • Generating anonymised evaluation data describing the uptake and impact of the programme;
  • Providing you with information on products, services, and news that we feel may be of interest to you, where you have given us your consent;
  • Promoting our services, including case studies and news items, where you have given us consent;
  • Sharing other relevant information, we feel would be of interest, in line with it meeting a specific legitimate interest; and
  • Notifying you about important legal changes to our Company and the services we provide (e.g. changes to this Privacy Notice).

6.2 IM HR Consulting Limited will record our purposes for personal data processing as part of our terms and conditions. 

6.3 IM HR Consulting Limited will only use your personal data for a new purpose if this is either compatible with the original purpose, or we obtain consent, or we have a clear lawful obligation or function set out in UK law.

6.4 Where relevant, IM HR Consulting Limited, may also share personal data with third parties, such as:

  • Trusted third party partners who we work alongside and who process personal data on our behalf, with regards to agreements and contracts, or for the provision of supplementary support services (e.g. data privacy, auditor, and information security partners);
  • Fraud prevention agencies, money laundering agencies, and other professional associations; and
  • Regulators and law enforcement agencies, including the Police, HM Revenue and Customs, or any other relevant authority who may have jurisdiction. We would always inform you ahead of acting on any instructions to proceed.

7.1 IM HR Consulting Limited always ensures the personal data we are processing is:

  • Adequate – sufficient to properly fulfil our stated purpose; 
  • Relevant – has a rational link to that purpose; and is
  • Limited to what is necessary – we do not hold more than we need for that purpose.

The UK GDPR does not define these terms. As this is the case, IM HR Consulting Limited accepts these terms may have a differing definition from one individual to the other, as the processing will depend on the specified purpose for collecting and using the personal data. 

7.2 In order to assess whether we are holding the right amount of personal data, we demonstrate clearly why we need it, before any data processing activities take place.

7.3 We treat information security very seriously. We will take all reasonable technical and organisational measures to prevent the loss, misuse or alteration of your personal information. Personal data is held securely on our systems, and we limit access to your personal data to those who have a business need to know. 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. No data transmission over the internet or any other network can be guaranteed as 100 per cent secure, but we take appropriate steps to try to protect the security of personal data.

7.4 IM HR Consulting Limited undertakes an annual Data Protection Audit with an external certified Data Protection Service Provider, to review our personal data processing, and to check that the personal data we hold is still relevant and adequate for the stated purposes.

8.1 IM HR Consulting Limited will take all reasonable steps to ensure the personal data we hold is accurate and up to date.

8.2 IM HR Consulting Limited will take reasonable steps to ensure that personal data we hold is not incorrect. This may involve contacting you via our official communication channels, to ensure all personal data held is accurate.

8.3 IM HR Consulting Limited will always record the source of where personal data came from and ensure the source is compliant with UK privacy laws, including the UK GDPR.

8.4 If we need to keep a record of a mistake, where we have clearly identified it as a mistake, we add this to our records of processing for audit purposes, and continuous improvement.

8.5 IM HR Consulting Limited records of processing clearly identify any matters of opinion, and where appropriate whose opinion it is, and any relevant changes to the underlying facts.

8.6 IM HR Consulting Limited will comply with the individual’s right to rectification, and carefully consider any challenges to the accuracy of the personal data.

9.1 IM HR Consulting Limited will not keep personal data for any longer than is necessary to fulfil the original stated purpose for the processing of such personal data.

9.2 Your data is only retained for as long as is necessary to fulfil the purposes we collected it for. Usually, your personal data is held for the duration of the contract and then for a further six years, in accordance with our data retention schedules.

9.3 IM HR Consulting Limited will only keep personal data for the period outlined to meet the requirements of the contract, legal obligation, or legitimate interest identified.

9.4 Any retention of personal data will be carried out in compliance with legal, professional body, and regulatory obligations. These data retention periods are subject to change, due to any revisions of associated legislation, regulations, or requirements.

9.5 IM HR Consulting Limited acknowledges that UK privacy legislation does not determine how long personal data needs to be kept. This is up to the Data Controller to determine and document accordingly at the earliest possible opportunity.

9.6 IM HR Consulting Limited has a personal Data Retention Policy in place, which documents the categories of personal data we hold, what we use it for, and how long we intend to keep it.

9.7 IM HR Consulting Limited periodically reviews the personal data we hold, and erases or anonymises it, when we no longer need to process it for the original purpose.

9.8 IM HR Consulting Limited also considers any challenges to the retention of personal data. We understand that individuals have a right to erasure if we no longer need their personal data.

9.9 IM HR Consulting Limited acknowledges there are exceptions to retention periods. Here we can keep personal data for longer if we are only keeping it for public interest archiving, scientific or historical research, or statistical purposes. We would always inform you if this was the case, along with our lawful basis for retention.

9.10 When IM HR Consulting Limited is provided with an instruction to destroy data it must be destroyed irretrievably either in paper or electronic formats. Paper records will be destroyed by an approved contractor who can provide evidence of destruction and a certificate of destruction. IM HR Consulting Limited will retain this certificate.

9.11 IM HR Consulting Limited also has secure destruction procedures and processes for any of the devices it has used for the storage of personal data. IM HR Consulting Limited will retain evidence of any equipment destruction and confirms that the destruction is beyond any prospect of retrieving data stored within the device.

10.1 IM HR Consulting Limited will undertake an analysis of the risks presented by our personal data processing and use this to assess the appropriate level of security we need to put in place. We review our Business Continuity Plan (BCP) and Incident Response Plan (IRP) annually.

10.2 IM HR Consulting Limited makes sure that we can restore access to personal data in the event of any data incidents or personal data breaches, by the implementation of an appropriate data backup procedure.

10.3 Where appropriate, we implement measures that adhere to an approved code of conduct or certification mechanism.

10.4 We ensure that any Data Processor we engage implements appropriate technical safeguards for all data.

10.5 IM HR Consulting Limited does track website behaviour in order to offer Data Subjects an enhanced client experience and for organisational analytics. The UK GDPR and PECR interprets data collected by cookies as personal. It prohibits the collection of personal data without consent, which means a website is only allowed to collect information that the user voluntarily inputs. The cookie consent must be freely given, specific, informed, and unambiguous.

11.1 Accountability is one of the UK GDPR data processing principles. IM HR Consulting Limited takes our accountability commitments with the UK GDPR very seriously, as documented by this Privacy Notice. 

11.2 IM HR Consulting Limited has put in place several measures that we can, and in some cases must take, including:

  • adopting and implementing data protection policies and procedures;
  • taking a ‘data protection by design and default’ approach;
  • maintaining documentation of our processing activities;
  • implementing appropriate security measures;
  • recording and, where necessary, reporting personal data breaches;
  • carrying out data protection impact assessments for uses of personal data that are likely to result in high risk to individuals’ interests;
  • ensuring all IM HR Consulting Limited employees and trusted partners receive annual UK GDPR and privacy legislation training;
  • appointing a certified and independent Data Protection Officer; and
  • adhering to relevant codes of conduct and signing up to certification schemes (where applicable).

11.3 IM HR Consulting Limited understands that accountability obligations are ongoing. We review and, where necessary, update the measures we have put in place. For example, we continually enhance our privacy management framework, as this can help embed our accountability measures and create a culture of privacy across our organisation.

11.4 IM HR Consulting Limited understands that being accountable can help build trust with individuals and may help mitigate any gaps in compliance, and thus any potential regulatory enforcement action.

11.5 If you have any questions or concerns about how we process and protect your personal data not covered in this Privacy Notice please contact the IM HR Consulting Limited DPO by email at [email protected]. 

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