DIVERSITY STUDY PRIVACY NOTICE
What is the purpose of this document?
The Diversity Study Group is an independent project, owned and operated by Halcyon Recruitment Limited. We have been engaged by your employer to produce a survey to gather information about diversity within the workplace. In the context of this survey, your employer and the Diversity Study Group are each “data controllers”. This means that each of us has responsibility for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are being asked to complete a survey as part of your employer’s Diversity Study. It makes you aware of how and why your personal data will be used, namely for the purposes of the Diversity Study, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
In connection with your completion of our Diversity Study, we will collect, store, and use the following categories of personal information about you (to the extent that you choose to provide information and responses to our questions gathering such information):
- Your gender, nationality, age and location.
- Your qualifications.
- The type of Company and industry you work in.
- Your job role, department and seniority.
- Any caring responsibilities.
- Your salary and the date and proportions of any increases.
- Any bonuses and their proportions.
- Your annual leave allowances.
- Any benefits or other incentives that you receive in connection with your employment.
- Training, development and promotion in your employment.
- Any changes to your job role and the reasons for it.
- Your knowledge, experience and opinions on diversity, discrimination, and inclusion practices in your workplace and your work environment.
- Your opinions on the culture within your workplace and working environment
- We may also collect, store and use the following types of more sensitive personal information:
- Information about your race, ethnicity or religious beliefs.
- Information about your health, including any disability.
We do not envisage collecting information about criminal convictions.
How is your personal information collected?
We collect this information about you from the responses you provide to the Diversity Study.
How we will use information about you
We will use the personal information we collect about you to:
- Pass anonymised data to your employer and other participating members of the study to allow them to assess the diversity of their workforce and to enable them to review their diversity practices.
- Compile, keep and utilise records about diversity within the maritime and shipping industries generally for the purposes of reporting to clients on general trends and in order to inform any advice or recommendations that we may give to other businesses generally.
It is in our legitimate interests to collect and process your information since it is beneficial to our business to increase our knowledge of diversity in relevant industries generally, and also to develop and provide Diversity Studies to promote diversity amongst our clients.
We also need to process your personal information in order to fulfil our contractual obligations to your employer to provide the Diversity Study and associated information and reports to them.
Please note that for any information gathered where we had responses from less than 10 participants, no data will be disclosed in relation to the responses received, to ensure anonymity is fully protected.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will share your personal information with your employer for the purposes of reporting on the results of the Diversity Study and for making any recommendations that we are asked to give. We will indirectly use any information we gather from the Diversity Study to inform any advice or recommendations that we provide to our other clients. In all cases, data provided to your employer will be shared in anonymised form.
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.
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.
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.
How long will you use my information for?
We will retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for. 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, regulatory, tax, accounting or other requirements. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
Where data is completely anonymised so it can no longer be associated with you, we may use this information indefinitely (eg. for research or statistical purposes) without further notice to you.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
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 copy of the personal information we hold about you 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 erasure of your personal information. 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- 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.
- Request the transfer of your personal information to another party.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you want to review, verify, correct or request erasure of your personal information, withdraw your consent or otherwise object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us by email sent to email@example.com and marked for the attention of our Data Protection Officer.