VAS Group understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our employees, workers, contractors, and consultants and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
For the purposes of this policy where we refer to VAS Group this incorporates Valuation Audit Services UK Ltd trading as VAS Assurance and VPanel trading as VAS Panel.
VAS Group is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
- Information About Us
|VPanel Ltd T/A VAS Panel
Registered in England under company number – 10893297
VAT number: 279643454
We are a member of The Association of Short Term Lenders (The ASTL).
|Valuation Audit Services UK Ltd (VAS Assurance)
Registered in England under company number – 09719651
VAT number: 222522842
We are regulated by Royal Institution of Chartered Surveyors (RICS).
We are a member of The Association of Short Term Lenders (The ASTL).
VAS Group registered / trading address is: Stephenson House, High Force Road, Riverside Park, Middlesbrough, TS2 1RH
Data Protection Contact- email@example.com
- What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
The personal data that we use is set out in Part 5, below.
We will comply with data protection law. This says that the personal information we hold about you must be:
a. Used lawfully, fairly and in a transparent way.
b. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
c. Relevant to the purposes we have told you about and limited only to those purposes.
d. Accurate and kept up to date.
e. Kept only as long as necessary for the purposes we have told you about.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e. The right to restrict (i.e. prevent) the processing of your personal data.
f. The right to object to us using your personal data for a particular purpose or purposes.
g. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to our relationship with you) set out in the table below to enable us to provide our products and or services.
|Data Collected||How We Collect the Data|
|Identity Information including Name, Title,||Application / Recruitment / Engagement|
|Contact information including Address, Email, Telephone Number||Application / Recruitment / Engagement|
|Business information Business Name, Job Title, Profession, Email, Telephone Number||Consultants Only – Engagement|
|Payment information including Card Details, Bank Account Number / Sort Code & Name, Card Holder Name||Employees – Confirmation of employment
Consultants – Conformation of Contract upon submission of invoice
|Emergency Contact Information||Upon employment employees only|
|Data from third parties – DBS Applications||Employees directly applies and evidence approved by HR.|
- How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We DO||What We Use||Our Lawful Basis|
|Administering your employment||Individual – Title, Name, Address, Telephone, Email, Bank Details, NI, Passport Number||Lawful Basis – Contract|
|Payroll||Name, Bank Details, NI, Tax Code||Lawful Basis – Contract|
|Communicating with you.||Individual – Title, Name, Address, Telephone, Email,||Lawful Basis – Contract|
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times.
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will / may be used for one or more the following purposes:
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).
- Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.
- Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits.
- Administering the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- Conducting performance reviews, managing performance and determining performance requirements.
- Making decisions about salary reviews and compensation.
- Assessing qualifications for a particular job or task, including decisions about promotions.
- Gathering evidence for possible grievance or disciplinary hearings.
- Making decisions about your continued employment or engagement.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
- Ascertaining your fitness to work.
- Managing sickness absence.
- Complying with health and safety obligations.
- To prevent fraud.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies to review and better understand employee retention and attrition rates.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Special Category Data
“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
We do not currently process special category data. In the event that the Company envisages that it will need to process special category data we will update this Policy immediately.
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
- We envisage that we will hold information about criminal convictions.
- We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
- Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
- Data Security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We retain information inline with HMRC and Regulatory requirements.
Further details pertaining to the specific retention periods can be found in our Data Retention Policy.
Any personal data we use for marketing purposes will be retained until you notify us that you no longer wish to receive this information.
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.
In some circumstances we may 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. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
- How and Where Do You Store or Transfer My Personal Data?
We will store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality and will only process on our instructions.
- procedures for dealing with data breaches (the accidental or unlawful destruction,
- loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
- Do You Share My Personal Data?
We may sometimes contract with third parties to supply products and / or services on our behalf E.G Payroll. These third parties will be bound by agreed terms and conditions with the VAS Group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
|Recipient||Activity Carried Out||Sector|
|Disclosure & Barring Service||DBS Checks||HM Government|
|RBS||IT Provider||Information Technology|
|Standard Life||Pension Payments||Financial|
|Canada Life||Death In Service Cover||Insurance|
|Vitality||Private Medical Insurance||Insurance|
|APS Global||Payroll provider||Financial|
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
These Recipients may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. However, they are contracted to take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and ensure it meets the minimum requirements of Data Protection Legislation. They must adhere to Binding corporate rules which set of their obligations in order to ensure compliance with UK GDPR.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.
We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures to stock exchange regulators and disclosures to shareholders such as directors’ remuneration reporting requirements.
- How Can I Access My Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request normally within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
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 another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- Right to withdraw consent
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 your 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.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Postal Address: Stephenson House • High Force Road • Riverside Park • Middlesbrough • TS2 1RH
- 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.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website https://vas-group.co.uk
This Policy has been approved & authorised: 26/02/2021
|Due for Review by:||2 Years|