This is the privacy notice of Rosekel Resourcing Ltd. In this document, "we", "our", or "us" refer to Rosekel Resourcing Ltd.
We are company number 07424653 registered in England and Wales.
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or any other information gathering business process.
- Referrals for support
For the purposes of the applicable Data Protection Laws, Rosekel Resourcing Ltd is the data controller of your personal data collected in connection with your use of, or interest in our services.
- Data we process
We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information includes information such as your address, email address, telephone numbers, family members names, contact address and telephone numbers and any other information you have given to us for the purpose of communication or supporting you with your direct payment or personal budget.
Your financial data includes, but not limited to, information such as your bank account details, your budget details and payment details and payroll details
Transaction data includes details about payments or communications to and from you and information about services you have purchased from us or a support provider.
Support Services data includes information relating to support delivered to you either by a provider (including Rosekel) where you are the customer or delivered by your personal assistant where you are a employer.
Technical data includes you internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
For example, we may aggregate customer data to assess level of service or demand.
However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
- Special personal information
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
It also includes information about criminal convictions and offences.
We may collect special personal information about you if there is a lawful basis on which to do so.
- Lawful basis and purposes of processing of your personal information
We collect information about you so that we can:
- Identify you and your account on our Customer Relationship Management System (CRM)
- Liaise with relevant partners on your behalf, including but not restricted to your funding body, HMRC, Pensions, Banking, Insurance etc
- Deliver bespoke support to help you manage your funding and support
- Improve our services
- Promote our business market our services
- Manage our business, including for accounting and auditing purposes
- Conduct our regular group reporting activities on the performance of our company, in the context of a business reorganisation or restructure
- Maintain our IT systems and manage hosting of our data
- Deal with any legal disputes involving you directly
- Prevent fraud
- Comply with our regulatory obligations
We will only use your personal information when the law allows us to, ie when it is necessary to:
- Perform our contractual obligations towards you, as set out in our contractual terms and conditions for support services
- Comply with our legal and regulatory obligations
- Pursue our legitimate interests (eg. Conducting our business in an efficient, compliant and profitable manner and the overall promotion of the business), and where your interests and fundamental rights do not override theses interests
- If you have provided us with your individual contact details (for example, your personal email address), we will rely on your consent to send you electronic communications such as our newsletters and emails with information about our services. If we hold business contact details (for example, your work email address), we will rely on legitimate interests of the business to send you electronic communications, but we will always provide you with an option to opt out from future communications of this kind.
Some of the above grounds and purposes for processing will overlap and there are maybe several grounds, which justify our use of your personal information.
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.
- If you do not provide personal information we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we will not be able to perform that contract. In that case, we will have to stop providing a service to you. If so, we will notify you of this at the time.
- The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you
When you receive a service from us, you agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information will be personal information.
We may use it in order to:
- communicate with you in response to a query or support requirement
- verify your identity for security purposes
- provide you with support to understand your responsibilities relating to a Direct Payment, Personal Budget or Personal Health Budget
- provide you with our support services, such as Recruitment and Employment Support. Payroll and a Managed Account Service if commissioned
- provide you with guidance and advice on our services, concerns you’ve raised and how to obtain the most from our support
- process your payroll, pensions contributions, completion of mandatory pre-employment checks and any other relevant requests in relation to your earnings
- on your request we will provide confirmation of earnings to support with housing and mortgage applications
- to ensure that our services are presented in the most effective manner for you according to your individual requirements and preferences.
We will process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
We will use the information we collect about your use of our website:
- to administer our website for internal operations, including operations, including troubleshooting, data analysis, testing research, statistical and survey purposes
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer and/or your mobile device
- to help us improve and personalise our services;
- to allow you to participate in interactive features of our website when you choose to do so
- as part of our efforts to keep our website safe and secure
- Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal information.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
- Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so
- Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
- Information relating to your method of payment
Payment information is never taken by us or transferred to through our website. Payment is made either directly to us via managed account by your funding body, or a bank transfer from yourself or via a personal cheque.
- Job application and employment
If we employ you or our customer employs you we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for up to 7 years before destroying or deleting it to ensure compliance with funding bodies and employment law.
- Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with our customers, personal assistants and partner agencies to provide a high quality service.
- Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise customers that you have referred to us and make necessary contact with and visit.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. This information is automatically anonymised, for further information on IP addresses please click https://support.google.com/analytics/answer/2763052?hl=en. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
- Disclosure of your information
We may allow our staff, consultants and/or external service providers acting on our behalf, and our provider of payment services, to access and use your personal data for the activities we have described above. We only permit them to use it to deliver the relevant service, and if they apply an appropriate level of security protection.
We will share your personal information with the following third parties:
- your funding providers in order to comply with contractual monitoring requirements, to which you have already provided permission
- relevant market regulators, inline with our business activities
- law enforcement agencies in connection with any investigation to help prevent unlawful activity
We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. 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.
We also reserve the right to disclose the information collected about you to our professional advisors and/or if we, in good faith, believe it necessary to protect the personal safety of users or the public.
We may share aggregated demographic information with our stakeholders. This is not linked to any personal information that can identify any individual person.
We may partner with another party to provide specific services. When you sign up for these services, we will share names or other contact information that is necessary for the third party to provide these services.
These parties are not allowed to use any personally identifiable information except for the purpose of providing these services. We may also use such aggregated information and statistics for monitoring the website usage in order to help us develop the website and our services and may provide such aggregate anonymous information to third parties.
- Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
- Data may be processed outside the European Union
Due to the nature of our business, it is highly unlikely that we would ever need to transfer your personal data outside the European Economic Area (EEA). However, in the event that we did, we will ensure that any transfer of your data will be subject to appropriate safeguards, such as a European Commission approved contract (if appropriate) that will ensure you have appropriate remedies in the unlikely event of a security breach.
Control over your own information
- Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
- Update, Access And Remove Your Personal Information
Updating Your Personal Information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.
Personal Information And Your Rights
Under certain circumstances by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
- 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 deletion of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend 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 we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
- Request the transfer of your personal information to another party.
If you would like to exercise any of the above rights please:
- Email, call or write to us (see our contact details below);
- Let us have proof of your identify and address (a copy of your driving licence or passport and a recent utility or credit card bill). This will allow us to verify your identity an prevent disclosure to unauthorised third parties;
- Inform us of the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.
Please note that if you request deletion, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to close our services and deactivate your account with us.
- Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
- Keeping your data secure
We have invested appropriate security measures to prevent your personal information from being accidently lost, used, or accessed in an unauthorised away, 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.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that is transferred by you via the internet. However, we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
We also use an encryption email and portal to exchange sensitive information and documents.
If you have any particular concerns about your information, please contact us (see our contact details above). We have put in place procedures to deal iwth 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.
- Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
- Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update or change this privacy notice from time to time as necessary. All changes will be outlined on this page and potentially on other pages of this website, informing you of the information we collect and how we use it at all times. Continued use of the Rosekel Website will constitute your agreement to any such changes.
- How and where to share concerns or complaints
When we receive a complaint, we record all the information you have given to us. We will use that information to resolve your complaint following our Complaints Policy and Procedures. A copy of both the Rosekel Complaints Policy and Procedures can be made available upon request.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done by contacting the ICO on 0303 123 1113 or https://ico.org.uk/make-a-complaint/. For more information about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit https://www.gov.uk/data-protection/the-data-protection-act .
We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.