Privacy Policy

Introduction

We are Easypay Services Limited (Registered in England & Wales No 05642779) of Victoria House, Bradford Road, Guiseley, Leeds LS20 8NH.

This Privacy Notice sets out the basis on which we use personal data in our business activities.

As a recruitment finance and back office service provider, we provide finance and back-office services to our Agency Partner. We are a Data Processor and our Agency Partner is the Data Controller. You should refer to the Agency Partner’s privacy notice to understand how your data will be stored and processed by them.

We are a Data Controller with regards to our internal staff and retaining personal data regarding our Agency Partner Shareholders and Directors.

This Privacy Notice applies to personal data which we may store about Agency Partner Representatives and Supplier Representatives in the course of our dealings with Agency Partners and Suppliers respectively.

As a business which operates as both a recruitment services provider and a recruitment finance business, data is critical to our business. Our systems and processes are designed to ensure that we can provide the best possible service to our clients while operating within the law at all times and protecting individuals’ data privacy rights.

We reserve the right to update this Privacy Notice from time to time. Where appropriate, we shall contact you to notify you of any material changes to the Privacy Notice. You should also refer to our website periodically so that you may access and view our updated Privacy Notice. This will ensure that you understand (i) how we are using your personal data and (ii) your legal rights around our usage of such personal data.

Who Should Read This Privacy Notice?

This Privacy Notice applies to any living, identifiable individuals about whom we may process personal data in the course of our business activities. You should read this Privacy Notice if you are:

  • An Agency Partner Representative
  • A Worker
  • A Client Contact
  • Supplier Representative

 

Please note that, in some cases, you will fall into more than one of the above categories.

If you are an employee, applicant for employment or in-house temporary worker, you should refer to our internal Privacy Notice instead. This is available to view on request.

Definitions

This Privacy Notice uses the following defined terms:

Agency Partner means a recruitment agency to which we are providing recruitment finance and back office services

Agency Partner Representative means a person who is employed or engaged by the Agency Partner and with whom we may deal in the course of providing services to the Agency Partner.

Client means a hirer which has engaged Easypay to provide recruitment services.

Client Contact means a person who is employed or engaged by a Client and with whom Easypay may liaise in respect of any services which Easypay is providing or wishes to provide to the Client. In some cases, the Client Contact and the Client may be the same person e.g. where a Client is a sole trader.

Data Protection Legislation means (i) the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.

Supplier means a business which provides services to Easypay and which may process personal data relating to any Candidate, Client Contact or Supplier Representative in the course of performing such services.

Supplier Representative means a person who is employed or engaged by a Supplier and with whom Easypay may liaise from time to time in respect of the services which are provided by that Supplier.

Third-Party Services Provider means any relevant third-party business which provides services to Easypay, including our:

  • Professional advisers including accountants, tax advisors and lawyers;
  • Insurers;
  • IT services providers and software providers;
  • Independent consultants and subcontractors

 

Worker means a person who is recorded in our records as being engaged by the Agency Partner to work on temporary assignments and who will be paid by the Agency Partner. Easypay will receive pay instructions from the Agency Partner and make arrangements to pay the worker in accordance with the instructions provided

How We Obtain Personal Data

We obtain personal data from a number of different sources, depending on the capacity in which you are dealing with us.

If you are a Worker, we may obtain personal data relating to you through our Agency Partner if you have worked on an assignment on behalf of the agency partner at a client and have been payrolled for an assignment through an agency partner.

If you are a Client Contact, Agency Partner Representative or Supplier Representative, we may obtain personal data relating to you:

  • Directly in the course of (i) us providing services to the Client (ii) us providing services to the Agency Partner or (iii) the Supplier providing services to us, as applicable; or
  • Indirectly from:
    • online professional networking sites such as LinkedIn
    • your employer’s website and other industry-related websites
    • business information directories
    • other individuals within your organisation in the course of (i) us providing services to the Client or (ii) the Supplier providing services to us, as applicable.
Types of Information We Hold

If you are a Worker, we may collect, store and process the following types of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your gender, date of birth, and place of residence;
  • Details of any position which you take up with a Client, including your role, duties, remuneration, department and location;
  • If you provide any services on a freelance basis:
    • Details of any limited company through which you contract and the nature of your relationship with that company;
    • Information about the days and times which you have worked;
    • Your bank details, tax code and National Insurance Number; and

 

If you are a Client Contact, we will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within the Client organisation; and
  • Any background information relating to your personal circumstances, your work history and the role which you perform within the Client which you may provide to us in the course of your dealings with us.

 

We do not collect, store or use any “special categories” of sensitive personal information if you are a Client Contact.

If you are an Agency Partner Representative, we will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within the Agency Partner organisation; and
  • Any background information relating to your personal circumstances, your work history and the role which you perform within the Agency Partner which you may provide to us in the course of your dealings with us.

 

We do not collect, store or use any “special categories” of sensitive personal information if you are an Agency Partner Representative.

If you are a Supplier Representative, we will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
  • Your job title and position within the Supplier organisation; and
  • Any background information relating to the role which you perform within the Supplier which you may provide to us in the course of your dealings with us.

 

We do not collect, store or use any “special categories” of sensitive personal information if you are a Supplier Representative.

How We Use Personal Data

If you are a Worker, we may use your personal data to make payments to you in respect of a temporary assignment or arrange for any third-party company through which you may contract to make payments to you.

If you are a Client Contact, we may use your personal data to:

  • Contact you to obtain information about our Client’s requirements;
  • Liaise with you so that we may effectively perform the services to our Client;
  • Contact you for invoicing and credit control purposes;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

 

If you are an Agency Partner Representative, we may use your personal data to:

  • Contact you to obtain information about the Agency Partner’s requirements;
  • Liaise with you so that we may effectively perform the services to our Agency Partner;
  • Contact you for invoicing and credit control purposes;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

 

If you are a Supplier Representative, we may use your personal data to:

  • Liaise with you in respect of the services which are being provided by the Supplier;
  • Contact you in relation to billing matters;
  • Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.
Our Lawful Basis for Processing Data

If you are a Worker we will use your personal data where you have agreed to perform a temporary assignment through our Agency Partner as we are responsible for paying your wages each week in accordance with the instruction received from our Agency Partner.

We have determined that we have a legitimate interest to process your personal data where you are:

  • Client Contact, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Clients. This will allow us to effectively provide services to them, better understand their requirements and generate revenue for our business.
  • An Agency Partner Representative, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Agency Partners. This will allow us to effectively provide services to them, better understand their requirements and generate revenue for our business.
  • Supplier Representative, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Suppliers. This will allow us to ensure that our Suppliers provide us with the best possible service which, in turn, is of direct benefit to both our Candidates and our Clients.
Where We Process Personal Data

Your personal data is held and processed by us in the United Kingdom.

We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches. We will therefore only transfer your personal data to jurisdictions outside of the EEA where:

  • There are binding corporate rules in place regarding the transfer of such data within the Group, in accordance with Article 47 of the GDPR. This means that the data transfer is between group companies and those group companies have agreed to share that data in accordance with the rules specified by the European Commission.
  • The European Commission has made an adequacy decision in respect of such jurisdiction. This means that the European Commission has pre-approved the data privacy regime in the relevant non-EEA country. At present, the European Commission-approved jurisdictions are Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework).
  • The transfer of data is subject to the model contractual clauses adopted by the European Commission. This means that we have a data-sharing agreement in place which complies with the requirements set out by the European Commission; or
  • You have expressly given informed consent to the transfer of such data. This means that you have not only agreed to the transfer but have done so in the knowledge that your data may be transferred to a jurisdiction which does not give you the same degree of protection as you have within the EEA.
Parties with Whom We May Share Data

If you are a Candidate, we may share your personal data for legitimate purposes with:

  • A third-party company through which you are contracting;
  • A third-party company to which you have specifically asked to be introduced or referred, such as an insurance company or intermediary (umbrella) company;
  • Industry bodies such as the Construction Industry Training Board and any similar organisations which are relevant to the market sector in which you work;
  • Our bankers and financiers;
  • Governmental departments and agencies where we are permitted or required by law to do so.

 

If you are a Client Contact or Agency Partner Representative, we will share your personal data with Third-Party Services Providers for legitimate business purposes only.

If you are a Supplier Representative, we will share your personal data with other Third-Party Services Providers for legitimate business purposes.

Our Website 

If you interact with our website at www.easypayservices.co.uk, we may process statistical information relating to your usage of the website and may capture certain information, including your IP address. For further information about how we use cookies for this purpose, please refer to our Cookie Policy at https://www.Easypay.Services/cookie-policy

Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

All decisions which are made in the course of our business processes involve human intervention. We do not therefore expect to make any decisions about you using automated means, whether you are a Candidate, Client Contact, Agency Partner Representative or Supplier Representative.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer at graham.pearson@easypayservices.co.uk

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

Data Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our standard data retention period is two years from the last date on which we are in actual contact with you i.e. where we actually speak with you or exchange correspondence. After this time, we will usually delete your personal data from our records.

Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for (i) seven years in respect of audit data which we may be required to produce for HRMC and (ii) six years in respect of any data which we may need to demonstrate compliance with our contractual obligations.

In some circumstances we may completely anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information. Under certain circumstances, you have the right to:

  • Request access to your personal information (a Subject Access Request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You will not usually have to pay a fee to access your personal information but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or you have objected to the processing and there is no overriding legitimate interest for continuing the processing.
  • Object to processing of your personal information where we are relying on a legitimate interest and you object on “grounds relating to your particular situation.”
  • Request the restriction of processing of your personal information. This enables you to ask us to block or suppress the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it or if you have also objected to the processing as above.
  • Request the transfer of your persnal information to another party when the processing is based on consent and carried out by automated means. This right is not usually applicable to any data processing carried out by Easypay.

 

If you want to exercise any of the above rights, please contact the Data Protection Manager in writing. We will consider your request and confirm the actions which we have taken in response to such request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We will confirm the actions which we have taken in respect of any such request.

 

If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the Information Commissioners Office in the United Kingdom. Their details are:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745

Email: casework@ico.org.uk

Contacting Us

If you have any questions about this Privacy Notice, you can write to the IT Manager at Easypay Services Limited, Victoria House, Bradford Road, Guiseley, Leeds LS20 8NH. Alternatively, you may telephone us on 01943 882129 or email us at graham.pearson@easypayservices.co.uk