EPM Global Ltd (“EPM”, “we”, “our”, “us”) takes your privacy very seriously. Please read this Privacy Policy carefully to see how EPM will treat the personal information that you provide to us either when using this website (the “Site”) or in other circumstances when we collect data from you (including via email). We will take reasonable care to keep your information secure and to prevent any unauthorised access or use of it. We process all information in accordance with applicable UK data protection legislation.
We may change this Privacy Policy from time to time and the change will take effect once the revised Privacy Policy is available on this Site. Therefore, please refer to this Privacy Policy each time you submit your personal information
We may ask you to provide information to us or collect date from you on different occasions, including at a number of points on the Site, such as when you:
The information that you are asked to provide will vary depending on the reason for the collection. In some instances, for example, if you purchase goods or services from us, the provision of certain information will be mandatory.
Please note that if you choose to participate in any discussion forum on the Site you may disclose personal information about yourself to other participants. If you do so this is at your own risk.
We will use your personal information:
If you become a customer of ours by purchasing goods or services from us we may send you further information that is related to your purchase, by post or e-mail or contact you by telephone.
We would like to send you marketing information, by post, e-mail, or SMS. By providing your information you are agreeing to EPM contacting you in this manner to provide you with such marketing information in accordance with the terms of this Privacy Policy.
If you do not wish to receive any of the above information or be contacted by us in accordance with the above, please update your preferences online (where this facility is available) or alternatively write to the Data Protection Officer at the address below.
If you contact us with your views or to make a general enquiry we will circulate them internally for training and management purposes. We may also publish your views on this Site or in other media. If you do not want us to do this, please let us know when you submit your views.
We may aggregate the information you send to us with other data (so that you cannot be identified from that data) and use that aggregated data for administrative purposes and/or share it with other people.
We will share your information with our affiliates and third party service providers if this is necessary or reasonably required for any of the purposes above. Such third party service providers are not entitled to use your information for their own purposes. Some of these third parties may be located outside of the United Kingdom, including in countries where data protection laws might not exist or be of a lower standard than the EU.
We are committed to protecting your privacy and we implement various security measures in relation to our processing and transfer of personal data. However, the nature of the Internet is such that the data may in some circumstances flow over networks without full security measures and could be accessible to unauthorised persons.
When you visit the Site, we may collect, process and use informing about you which may not personally identify you but which my be helpful for improving the operation of the Site. Such information may be collected through “traffic data” and may entail the use of “cookies”, “IP Addresses” or other numeric codes used to identify your computer. You can delete cookies or configure your computer to reject them, although this may disable the Site’s ability to manage individual sessions.
This Site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of these sites. We encourage our users to be aware when they leave this Site and to read the privacy statements applicable on those sites. This privacy policy does not apply to information collected on third-party sites.
You have the right to access the information that EPM holds about you in accordance with the Data Protection Act 1998. In order to do this please make a written application to the Data Protection Officer, at the address provided below. EPM may require you to provide verification of your identity to provide a copy of the information that it holds. Please note that in certain circumstances EPM may withhold access to your information where it has the right to do so under current data protection legislation.
In the event that there is a change to your personal information for example your contact details, please let us know of this by updating your details online (where this facility is available) or writing to the Data Protection Officer, at the address provided below, so that we can keep your information up to date and accurate.
If you have any queries about this Privacy Policy, wish to stop being contacted by EPM or you wish to access or update your information please email EPM at office@epmgpartners.com
We may have to collect and use information about people with whom we work. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.
This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data that relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.
Specifically, we hold the following types of data:
Information relating to your employment with us, including:
All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.
You have the following rights in relation to the personal data we hold on you:
More information can be found on each of these rights in our separate policy on employee rights under GDPR.
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.
We have also appointed employees with responsibility for reviewing and auditing our data protection systems.
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.
However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed, and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
Further information on making a subject access request is contained in our Subject Access Request policy.
The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:
These kinds of disclosures will only be made when strictly necessary for the purpose.
All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.
Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it should be coded, encrypted or password-protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.
Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
The Company may be required to transfer personal data to a country/countries outside of the EEA. Transfers may take place because (provide details on why transfer may have to take place). Where this occurs, the following safeguards are adopted (insert details eg binding corporate rules/standard data protection clauses/compliance with an approved code of practice etc).
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
More information on breach notification is available in our Breach Notification policy.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.
Our appointed compliance officer in respect of our data protection activities is:
Damian Zielinski – EPM Global Ltd
Email: office@epmgpartners.com Tel: +44 (0) 2071 268 382